OppositionOppositionCal. Super. - 4th Dist.August 2, 2016OO 0 9 NY Wn ps W N ee N N N N N N N N N = mm e m e m p m pe e e m e d be d cw ~~ O N n h BR W N = O N O Y B W NY e s OO Bradley P. Knypstra (State Bar No. 177901) brad@khtriallawyers.com Robert A. Zermeno, Jr. (State Bar No. 239108) robert@khtriallawyers.com Grant Hermes (State Bar No. 291822) grant@khtriallawyers.com KNYPSTRA HERMES LLP 2731 2 E. Coast Highway Corona Del Mar, CA 92625 Tel: (949) 432-3802 Fax: (949) 432-3803 Jeffrey S. Dawson (State Bar No. 147847) jeff@pi-attorney.com LAW OFFICES OF JEFFREY S. DAWSON A Professional Corporation 9841 Irvine Center Drive, Suite 210 Irvine, California 92618 Tel: (949) 861-2191 Fax: (949) 861-2190 Attorneys for Plaintiff David Talpos SUPERIOR COURT OF CALIFORNIA COUNTY OF ORANGE DAVID TALPOS, by and through his Guardian ad Litem, IOANA SIMONA TALPOS; Plaintiff, v. FULLERTON JOINT UNION HIGH SCHOOL DISTRICT, LA SIERRA HIGH SCHOOL, ENDEAVOR HIGH SCHOOL, and DOES 1 through 100, inclusive, Defendants. Case No.: 30-2016-00867178 [Unlimited Civil Case assigned for all purposes to the Hon. Judge Richard Y. Lee, Dept. C32] OPPOSITION TO DEFENDANT’S EX PARTE APPLICATION TO SPECIALLY SET AN EARLIER HEARING ON DEFENDANT’S MOTION FOR LEAVE TO AMEND ITS EXPERT WITNESS DESIGNATION Complaint Filed: August 2, 2016 Trial Date: April 13,2020 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: Plaintiff David Talpos (“Plaintiff”) hereby submits the following opposition to Defendant Fullerton Joint Union High School Districts’ (“Defendant”) ex parte application to specially set an OPPOSITION TO DEFENDANT'S EX PARTE APPLICATION -1- OO © ~~ O N Wn pA W N N R N N N NN N N N e m m a e m e m em pe d pe d p m pe p m «Ww N y Un R W ND = D O O O Y R W W ND = o earlier hearing on Defendant’s motion for an order granting leave to amend its expert witness designation and declaration. I NO EXIGENT CIRCUMSTANCES EXIST TO SHORTEN TIME TO HEAR DEFENDNT’S MOTION AS DEFENDANT HAS A MARCH 12, 2020 MOTION DATE AND TRIAL WOULD LIKELY HAVE TO BE CONTINUED IF THE COURT GRANTS THE MOTION Good cause does not exist to shorten time and hear Defendant’s motion to amend its expert witness designation as Discovery in this matter closed long ago. As discussed below, both parties mutually participated in expert discovery and continued the prior December 2018 trial date for the sole reason of mediating the case. If the Court entertains Defendant’s Ex Parte Application to shorten time the parties can fully brief the issue prior to the March 12, 2020, motion date. IL. INITIAL CCP §2034 TOOK PLACE ON OCTOBER 22, 2018, EXPERT DEPOSITIONS HAVE BEEN TAKEN, AND NOW NEW DEFENSE COUNSEL, 15 MONTHS LATER, WANTS TO DESIGNATE NEW EXPERTS A. According to CCP §2034.620 a Moving Party Must Bring Their Motion Promptly, Not 15 Months After a Timely Exchange. The Complaint in this matter was filed on August 2, 2016. After almost two years of litigation a trial date was scheduled for December 10, 2018. On September 26, 2018, the parties served CCP §2034 demands. On October 22, 2018, both parties mutually exchanged expert witness designations, including declarations. See Exhibits 1 and 2. The supplemental exchange cutoff was November 13, 2018, and neither party supplementally designated. Just days away from the December 10, 2018, trial date, on November 21, 2018, the parties agreed to stipulate to continue the trial date in order to allow the parties to attend a mediation on January 17,2019. That was the sole reason for the continuance as the parties were geared up for trial, all discovery cutoff dates had passed, and the parties were beginning to complete expert depositions. As part of that stipulation, which is attached as Exhibit 3, the parties agreed that all discovery cutoff dates would be based on the December 10, 2018, trial date “except the parties stipulate to completing OPPOSITION TO DEFENDANT'S EX PARTE APPLICATION 3. Oo 0 1 O N wn B R A W N N N N N N N N N N m m e m p m p e d pe d be d pe ed expert deposition discovery by two weeks prior to the trial date.” As evidence of this, the expert depositions began with the plaintiff taking defendant’s sole expert, Board Certified Orthopedic Surgeon, Kendall Wagner, M.D.’s deposition on November 26, 2018. At that time, Defendants noticed the Plaintiff’s experts’ depositions for November 20, 2018, but they chose to take those depositions off calendar because of the anticipated trial continuance. To date, Defendant has not re- noticed the Plaintiff’s experts’ depositions. Of note, Dr. Wagner was designated to, and did, provide opinions regarding the Plaintiff’s injuries, causation and damages. On May 7, 2019, the parties again stipulated to continue trial due to defense counsel’s pre- planned vacation and it was agreed that all discovery cutoff dates would be based on the July 7, 2019, trial date “except the parties stipulate to completing expert deposition discovery by two weeks prior to the trial date.” See Exhibit 4. Here, however neither party resubmitted CCP §2034 demands because as stipulated in the first stipulation, on November 21, 2018, expert discovery was complete except for the depositions of plaintiff's experts. On May 13, 2019, this Court continued the trial with an Order that no further trial continuances would be granted. Now, some fifteen months later, for the first time, Defendant is trying to unilaterally re-open expert discovery and amend/supplement its prior expert designation with four new retained experts and 25 new non-retained experts, based on the retention of new counsel, in spite of the fact that it previously stipulated that the 30-day discovery cutoff and the 15-day expert discovery cutoff dates have long passed. Contrary to Defendant’s position, allowing it to unilaterally re-open expert discovery and call witnesses not identified in its original Expert Witness Designation will no doubt result in surprise, prejudice, and an injustice at trial B. Plaintiff will be Prejudiced if Defendant is Allowed to Add 4 New Retained Experts and 25 New Non-Retained Experts, which will Require Re-opening Expert Discovery, Counter Designation and a Trial Continuance, Even Though This Court Ordered No Further Trial Continuances on May 13, 2019. As shown above, this case was days away from trial in November of 2018, when the parties agreed to continue trial for the sole purpose of attending a mediation. Essentially, all discovery was OPPOSITION TO DEFENDANT'S EX PARTE APPLICATION 3- OO 0 9 NN nn Bs W N N O N ND N N N N N N m e em e s e m ee a RW N N nn BR W N = O 0 0 N N O Y R W N = Oo completed in November of 2018, except for the depositions of Plaintiff’s properly designated experts. Now, Defendant seeks to unilaterally re-open expert discovery to designate four new retained experts and 25 new non-retained experts. The economic cost and logistics of completing this substantial expert discovery will no doubt prejudice the Plaintiff. In addition to taking the retained experts’ depositions, the Plaintiff would be forced to potentially take the depositions of some, if not all, of the 25 newly identified non-retained experts. Additionally, the Plaintiff may be forced to supplementally designate their own additional expert witnesses. Just because new counsel does not like the expert/s designated by their co-counsel, and the testimony provided by that witness, is not good cause to re- open expert discovery and prolong this litigation. Defendant argues that the Plaintiff would not be prejudiced because they have already retained expert witnesses in the fields of “physiatry, life care planning, and biomechanics.” This argument must fail because Defendant has known about these experts since October 22, 2018, and it was not until December of 2019, that they decided to address this. Because Defendant chose not to properly comply with CCP §2034, and supplementally designate expert witnesses that it found appropriate, the Plaintiff should not be unduly prejudiced with having to face a Defendant who is a constant moving target. Defendant mistakenly assumes that the addition of four new retained experts and 25 new non- retained experts will not affect the parties” ability to prepare for trial. However, unlike defense counsel, Plaintiff’s counsel is set to begin a two-week trial in San Mateo, California on January 21, 2020 and a four-week trial in Orange County beginning on March 2, 2020. Therefore, if Defendant is allowed to amend/supplement its expert designation this will undoubtedly require the trial date to be continued, which would be in direct violation of this Court’s May 13, 2019, Order that there be “no further continuances.” See Exhibit 4. Tactics and behavior such as those shown above are the reason why the Code of Civil Procedure put limits and provisions on expert designation. The prejudice to the Plaintiff in this case would be undeniable if Defendant were allowed to amend/supplement their expert designation at this stage in the litigation. OPPOSITION TO DEFENDANT'S EX PARTE APPLICATION -4- OO 0 N N nn R W N = N N ND N R R R N D R D ee e m he e e e e ee e m e e a 0 NN A hh R R W N = O O N Y BR W N = O III. CONCLUSION For the reasons stated above, Defendant’s respectfully request this Court to deny Defendant’s ex parte application and deny their Motion to amend their expert designation. Dated on this 13" day of January, 2020 by: Knypstra Hermes LLP Bradl¢§ P"Knypst ra, Attorney for Plaintiff OPPOSITION TO DEFENDANT'S EX PARTE APPLICATION -5- NO 0 9 O N n n Ase W N B R O N DN O N N N N N N m m m t m d p e m e d p e d e d pe ed pe ed pe d c o N y nn RA W N = O 0 0 NN SY N R R L ND - O DECLARATION OF BRADLEY P. KNYPSTRA I, Bradley P. Knypstra, declare and state as follows: 1. Iam an attorney duly licensed to practice law in the State of California. I am employed by Knypstra Hermes LLP and am one of the attorneys of record for Plaintiff David Talpos in the instant matter. I am one of the custodians of records for Knypstra Hermes LLP. I have personal knowledge of the matters declared herein and can competently testify thereto if called upon to do so. 2. Attached as Exhibit 1 is a true and correct copy of Plaintiff’s Expert Designation dated October 22,2018 that I received and maintained in the ordinary course of business. 3. Attached as Exhibit 2 is a true and correct copy of Defendant’s Expert Designation dated October 22, 2018 that I received and maintained in the ordinary course of business. 4. Attached as Exhibit 3 is a true and correct copy of the executed Stipulation and Order to continue trial dated November 21, 2018 that I received and maintained in the ordinary course of business. 5. Attached as Exhibit 4 is a true and correct copy of the executed Stipulation and Order to continue trial dated May 7, 2019 that I received and maintained in the ordinary course of business. 6. Just days away from the December 10, 2018, trial date, on November 21, 2018, the parties agreed to stipulate to continue the trial date in order to allow the parties to attend a mediation on January 17, 2019. That was the sole reason for the continuance as the parties were geared up for trial, all discovery cutoff dates had passed, and the parties were beginning to complete expert depositions. 7. 1am set to begin a two-week trial in San Mateo, California on January 21, 2020 and a four- week trial in Orange County beginning on March 2, 2020. I declare under penalty of perjury under the laws of the State of California that the foregoing is 7) Dated on this 13" day of January, 2020 by: / / [F fo, 7 7 Bradley P. fnyste true and correct. Executed in Corona Del Mar, California. OPPOSITION TO DEFENDANT'S EX PARTE APPLICATION -6- EXHIBIT “1” NO 0 0 N N nn B W N e N O N O N N O R RN N O N O N re m r m m m e t be m p d e d pe t b m pe G 0 N I N hh B W O N em O W N N l R W e o Bradley P. Knypstra (State Bar No. 177901) brad@khtriallawyers.com KNYPSTRA HERMES LLP 2731 %2 E Coast Hwy Corona Del Mar, CA 92625 Tel: (949) 432-3802 Fax: (949) 432-3803 Jeffrey S. Dawson (State Bar No. 147847) jeff@pi-attorney.com LAW OFFICES OF JEFFREY S. DAWSON A Professional Corporation 9841 Irvine Center Drive, Suite 210 Irvine, California 92618 Tel: (949) 861-2191 Fax: (949) 861-2190 Attorneys for Plaintiff David Talpos SUPERIOR COURT OF CALIFORNIA COUNTY OF ORANGE DAVID TALPOS, by and through his Guardian ad] Case No.: 30-2016-00867178 Litem, [OANA SIMONA TALPOS; [Unlimited Civil Case assigned for all purposes to Plaintiff, the Hon. Judge Richard Y. Lee, Dept. C32] v. PLAINTIFF’S DESIGNATION OF EXPERT WITNESSES FULLERTON JOINT UNION HIGH SCHOOL DISTRICT, LA SIERRA HIGH SCHOOL, ENDEAVOR HIGH SCHOOL, and DOES 1 Complaint Filed: August 2, 2016 through 100, inclusive Trial Date: December 10, 2018 Defendants. TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: Plaintiff David Talpos (“Plaintiff”) hereby designates the following list of expert witnesses who may be called by counsel to testify at the time of trial on December 10, 2018 as required under Cal. Code Civ. Proc. § 2034.010. Plaintiff reserves the right to retain additional expert witnesses should it become necessary after further investigation and discovery, including the deposition testimony of various witnesses involved herein. PLAINTIFF'S DESIGNATION OF EXPERT WITNESSES -1- OW LO I ON Bb W R ee B O N N N N N N N N = me w e m m e le e e d b e d p e d e t ee d RX N N Ln RA W N = O Y O N Y R A W N = Oo Plaintiff reserves the right to call any and all parties, their employees or in-house expert witnesses. Plaintiff reserves the right to read the deposition of any of the below-mentioned witnesses who have testified, or call at the time of trial, any and all of these witnesses under Cal. Evid Code § 776 and to elicit from these witnesses any and all expert testimony that they may be competent to give. Subject to the foregoing, Plaintiff hereby designates the following retained experts and/or non- retained experts known and contemplated for use at the time of trial, some or all of whom may be called by Plaintiff to testify at the time of trial and render opinion testimony: RETAINED EXPERTS 1. David E. Fish, MD/MPH 1350 Davies Dr., Beverly Hills CA, 90210, 310.403.1347 2. Anatol Podolsky, MD 400 Newport Center Dr., Suite 601, Newport Beach, CA 92660, 949.644.6882 3. Stephanie Bonin, PhD, PE 23281 Vista Grande Drive #A, Laguna Hills, CA 92653; Tel 949.855.4632 NON-RETAINED TREATING EXPERTS Plaintiff reserves the right to elicit expert testimony from any and all of Plaintiff’s treating physicians, therapists, nurses, and medical care consultants, who in addition to their knowledge as percipient witnesses, may be asked to render expert opinions. This reservation is to include the following: 1. Laura E. Petrovich, MD CHOC Children’s Clinic, 1201 W. La Veta Ave., Orange, CA 92868, 888.770.2462 2. Justin Pick, MD CHOC Children’s Clinic, 1201 W. La Veta Ave., Orange, CA 92868, 888.770.2462 3. Greg Middleton, DC Complete Wellness Center, 15112 Rosecrans Ave., La Mirada, CA 90638, 714.522.2332 PLAINTIFF'S DESIGNATION OF EXPERT WITNESSES 2 OO 00 N N O N nn B W N O N N N N R N N N = se m p m ee e a pe t e m p d pe d pe WwW 3 NN nh B W N N = O O N N Y R W OO 4. Alvaro Liceaga, MD Complete Wellness Center, 15112 Rosecrans Ave., La Mirada, CA 90638, 714.522.2332 5. Gabriel Ramirez, MD 301 W. Bastanchrury Road, Suite 130, Fullerton, CA 92835, 714.278.9363 6. Brea Dental Group Person Most Qualified 503 E. Imperial Hwy, Brea, CA 92821, 714.672.9000 Plaintiff reserves the right to elicit expert testimony from any and all other percipient witnesses, who in addition to their knowledge as percipient witnesses, may be asked to render expert opinions. Plaintiff further designates each and every expert witness called and/or consulted by any party in this action. Plaintiff also retains the right to amend, modify, or supplement this list pursuant to the provisions of Cal. Code Civ. Proc. § 2034.210 et seq. and specifically reserve the right to withdraw any and/or all of the foregoing expert witnesses in this action. By designating the foregoing individuals as expert witnesses, Plaintiff does not hereby intend to waive either the attorney/client privilege or work product privilege that may presently exist. If any of the witnesses discussed or listed above are not available at the time of trial, Plaintiff hereby advises all parties that Plaintiff will seek the introduction of completed testimony, including depositions, of such witnesses in lieu of their testimony. Dated on this 22™ day of October, 2018 by: Knypstra Hermes LLP Bradley P. Knypstra, N Attorney for Plaintiff PLAINTIFF'S DESIGNATION OF EXPERT WITNESSES -3= NO 0 0 N1 3 O y o x W N ) DN RN DN DN BR N N N O N mm mm m m em em pe d pe d p d ee d pe w © 93 Lh A W N = O Ww N N N R W = O DECLARATION OF BRADLEY P. KNYPSTRA I, Bradley P. Knypstra, declare and state as follows: 1. I'am an attorney duly licensed to practice law in the State of California. I am employed by Knypstra Hermes LLP and am one of the attorneys of record for Plaintiff David Talpos in the instant matter. I am one of the custodians of records for Knypstra Hermes LLP. I have personal knowledge of the matters declared herein and can competently testify thereto if called upon to do so. 2. All of the following retained experts have agreed to testify at the trial of this matter and will be sufficiently familiar with the pending action to submit to meaningful oral deposition concerning any opinions and the basis for those opinions. a. David E. Fish, MD/MPH: As to this expert, I am informed and believe the following is true and correct: i. i. David E. Fish, MD/MPH whose address is 1350 Davies Dr., Beverly Hills, CA 90210, is a Board Certified specialist in Physical Medicine and Rehabilitation and Pain Medicine. Dr. Fish has agreed to testify as an expert in this matter and will be sufficiently familiar with the pending action to submit to a meaningful oral deposition concerning this expert’s opinions and the basis therefore. Dr. Fish’s Curriculum Vitae is attached hereto as Exhibit “1”. Dr. Fish will testify regarding the nature and extent of Plaintiff's injuries sustained in the accident of August 14, 2015, including but not limited to his knees, hips, neck and back, chin, and other related body parts at issue, and the medical care and treatment obtained and to be obtained; diagnosis of injury; prognosis; need for past and future medical treatment and/or surgery; causation issues regarding the injuries and need for past and future medical treatment and/or surgery; reasonableness and necessity for the medical care and related expenses; the findings of the diagnostic testing, x-rays, MRI's, etc.; Plaintiff's physical condition, symptoms, and disabilities since the accident to the present and in the future; Plaintiff’s physical condition before the accident; and the PLAINTIFF'S DESIGNATION OF EXPERT WITNESSES -4- Ov 0 9 A hh h Bs W N N O N N N N N N N N = e s e m ee e e p m ee pe b e WW N A N Wn bh W N ee O V W NN S Y D W N -- oO iii. effect Plaintiff’s injuries would be expected to have on day-to-day living, recreation, and activities. Dr. Fish will also testify regarding the reasonable and necessary future care and life expectancy of Plaintiff, Plaintiff’s long term future rehabilitation, vocational, educational and other needs and costs as they relate to Plaintiff's life care plan and case management and Plaintiff's current medical conditions. Dr. Fish’s hourly fee for providing deposition testimony at his office is $1,200.00 per hour with a 2 hour minimum prepaid prior to his deposition. Dr. Fish’s fee for providing video tapped deposition is $2,500.00 per hour with a 2 hour minimum prepaid prior to his deposition. b. Anatol Podolsky, M.D.: As to this expert, [ am informed and believe that the following is true and correct: i. il. Anatol Podolsky, M.D. whose office is located at 400 Newport Center Dr. Ste. 601, Newport Beach, CA 92660; Tel 949.644.6882, is a Board Certified Orthopedic Surgeon and Fellow of American Academy of Orthopedic Surgery. Dr. Podolsky has agreed to testify as an expert in this matter and will be sufficiently familiar with the pending action to submit to a meaningful oral deposition concerning this expert’s opinions and the basis therefore. Dr. Podolsky’s Curriculum Vitae is attached hereto as Exhibit “2”. Dr. Podolsky will testify regarding the nature and extent of Plaintiff's injuries sustained in the accident of August 14, 2015, and the medical care and treatment obtained and to be obtained; diagnosis of injury; prognosis; need for past and future medical treatment and/or surgery; causation issues regarding the injuries and need for past and future medical treatment and/or surgery; reasonableness and necessity for the medical care, surgery, and bills; the findings of the diagnostic testing, x-rays, MRI's, etc.; Plaintiff’s physical condition, symptoms, and disabilities since the accident to the present and in the future; Plaintiff’s PLAINTIFF'S DESIGNATION OF EXPERT WITNESSES 4. OO 0 N N nh D W N 0 ~l aN w h ££ Ww No So oS \ O o o <2 AN | . ) HS w y N o od oO 7 physical condition before the accident; and the effect Plaintiff's injuries would be expected to have on day-to-day living, recreation, work, and activities. ii. Dr. Podolsky’s hourly fee for providing deposition testimony in his office is $900.00 per hour (2 hour minimum reserved time due and payable at the beginning of the deposition). c. Stephanie Bonin, PhD, PE: As to this expert, I am informed and believe that the following is true and correct: i. Stephanie Bonin, PhD, PE whose office is located at 23281 Vista Grande Drive #A, Laguna Hills, CA 92653; Tel 949.855.4632, is a Registered Professional Engineer. Ms. Bonin has agreed to testify as an expert in this matter and will be sufficiently familiar with the pending action to submit to a meaningful oral deposition concerning this expert’s opinions and the basis therefore. Ms. Bonin’s Curriculum Vitae is attached hereto as Exhibit “3”. ii. Ms. Bonin will testify regarding the biomechanics of Plaintiff's accident, including but not limited to causation, reconstruction, impact, forces and severity of Plaintiff's accident. Ms. Bonin is also expected to offer testimony in response to any other testimony offered by Plaintiff’s experts, including but not limited to opinions on any of the topics noticed above. iii. Ms. Bonin’s hourly fee for providing deposition testimony in her office is $250.00 per hour (.1 hours minimum time increment). 3. The treating physicians named within this designation will render expert medical opinions regarding the examination, evaluation, diagnosis, treatment (past, present, and future), prognosis (past, present, and future), care of Plaintiff, long term needs of Plaintiff, pain and suffering of Plaintiff (past, present, and future), and the reasonableness and necessity of the care and treatment (past, present, and future) and the related bills and costs. They will further render expert opinions regarding causation of these injuries and damages claimed by Plaintiff, and will provide rebuttal testimony to any other expert testimony regarding these or other related issues. PLAINTIFF'S DESIGNATION OF EXPERT WITNESSES -6- OO 60 NN O N hn px Ww DN 10 11 2 13 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4. The witnesses designated as percipient witnesses may be asked to render expert opinions to the extent they qualify as an expert in any specific filed of relevance, including but not limited to the investigation and evaluation of the incident giving rise to this litigation. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed in Corona Del Mar, California. / Dated on this 22™ day of October, 2018 by: \ “Bradley P. Knypstra hy PLAINTIFF'S DESIGNATION OF EXPERT WITNESSES -7- EXHIBIT “1” DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills Ca 90210 T: (310) 403-1347 Email: davidfishmd@gmail.com APPOINTMENTS UCLA SCHOOL OF MEDICINE Los Angeles, CA 2002 - Present Professor, Dept. of Orthopaedics UCLA - GLA VA WLA Los Angeles, CA 2002 - Present Assistant Program Director, Pain Medicine Fellowship VETERANS ADMINISTRATION HOSPITAL Los Angeles, CA 2001 - Present Consulting Physician, Physical Medicine and Rehabilitation CERTIFICATION American Board of Physical Medicine and Rehabilitation [ABPMR] Board Certified June 2002 Electrodiagnostic Medicine. Brain Injury, Spinal Cord Injury, Sports Medicine Pain Medicine, ABPMR and American Board of Anesthesia [ABA] Board Certified October 2003 MEDICAL BOARDS Nevada Board of Medical Examiners ACTIVE (12908) October 2008 Medical Board of California ACTIVE (A 77878) February 2002 Maryland Board of Physician Quality Assurance INACTIVE (D0054876) September 2002 FELLOWSHIP UCLA MULTICAMPUS, Division of PMR Los Angeles, CA 2001 - 2002 PAIN MEDICINE RESIDENCY THE JOHNS HOPKINS MEDICAL CENTER / SINATI HOSPITAL OF BALTIMORE PHYSICAL MEDICINE AND REHABILITATION 1998 - 2001 Chief Resident 2000 - 2001 MEDICAL EDUCATION FITZSIMMONS ARMY MEDICAL CENTER Denver, CO 1994 - 1995 TRANSITIONAL INTERNSHIP NEW YORK MEDICAL COLLEGE Valhalla, NY 1990 - 1994 COMBINED MD / MPH DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills Ca 90210 T: (310) 403-1347 Email: davidfishmd@gmail.com COLLEGE EDUCATION UNIVERSITY OF CALIFORNIA AT BERKELEY 1983 - 1988 Bachelors of Arts in RHETORIC and PHYSIOLOGY EXPERIENCE US ARMY Wiesbaden, Germany 1995 - 1998 General Medical Officer: General practitioner in a U.S. military medical clinic. Thirty thousand active duty troops with dependents, retired military, and DOD civilians. Honorably Discharged 2001 attaining rank of Captain. OPERATION JOINT ENDEAVOR Former Yugoslavia Jan. - Nov. 1996 Deployed as a Medical Officer: Support emergency and routine health care for Task Force Eagle. KAISER PERMANENTE HOSPITAL San Rafael, CA 1987 - 1990 Physical Therapy Aide: Inpatient acute care and outpatient Orthopaedic rehabilitation. AWARDS DISTINGUISHED CLINICIAN June 2002 UCLA/ WLA VA Multicampus Physical Medicine and Rehabilitation Residency June 2009 Selected by UCLA Residents as the distinguished staff attending for the academic year. June 2012 FPMR BEST RESEARCH PAPER October 2004 Foundation for Physical Medicine and Rehabilitation Selected as the best paper of the year at the National Academy Meeting for PM&R published in any peer review journal for a Physiatrist in practice for less than 5 years by the Board of Physical Medicine and Rehabilitation. UCLA TEACHING EXCELLENCE IN PROBLEM BASED LEARNING 2007 - 2014 Award given to distinguished physician out of more than 400 participating faculty. Voted by medical students for excellence in teaching 1* year curriculum Block 4. Seven years in a row achieving this award. Southern California SUPER DOCTORS* 2012 - 2016 Listed in Los Angeles Magazine as a ‘doctor’s doctor.” Super Doctors* is a respected publication that identifies top doctors through independent research and an objective selection process. PROFESSIONAL ORGANIZATIONS American Academy of Physical Medicine and Rehabilitation, Board Certified (6949) Member since 1997 Physiatric Association of Spine, Sports and Occupational Rehabilitation (PASSOR) Discontinued Group Spine Interventional Society (Formally ISIS) Member since 2003 Association of Academic Physiatrists Member since 2004 North America Spine Society Member since 2005 North American Neuromodulation Society Member since 2009 DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills Ca 90210 T: (310) 403-1347 Email: davidfishmd@gmail.com COURSE DIRECTOR AND EDITOR POSITIONS Non-Operative Musculoskeletal And Spine Pain Management 2002 - present David Geffen School of Medicine at UCLA Multidisciplinary non-operative musculoskeletal and spine pain management team. Students have an opportunity to participate in the evaluation of both chronic and acute musculoskeletal and spine pain patients under the supervision of a multidisciplinary team. This includes medication management, physical therapy, psychological assessment, interventional procedures, peripheral nerve diagnosis with Electromyography and the development of a comprehensive management plan for musculoskeletal and spine patients. UCLA Spine Center 2002 - present David Geffen School of Medicine at UCLA The Comprehensive Spine Center at UCLA consists of a multidisciplinary team that approaches all types of spinal disorders. Students will have a unique opportunity to participate in the evaluation of both operative and non-operative spine patients under the supervision of each member of the multidisciplinary team. Clinical Physical Examination Testing 2002 - present David Geffen School of Medicine at UCLA Responsible for testing and teaching of third year medical students for physical examination technique for requirement to start the third year rotations in clinical medicine. The course involves groups of ten medical students at each session to review clinical examination techniques. Musculoskeletal, Neurology, and Psychology Block 4 2004 - present David Geffen School of Medicine at UCLA The course curriculum for first year medical students includes organization of core competencies, laboratory teaching, and general lectureship in the areas of musculoskeletal, pain, neurology, sports medicine, and electrodiagnostic medicine. 150 medical students were enrolled for the course each year for 8 weeks. Responsible for Problem Based Learning discussion groups leadership. Current Reviews in Musculoskeletal Medicine 2007 - present Editorial Board Member responsible for content and review of original articles on the subject of musculoskeletal medicine. Biologics and Basic Science Section Spine 2008 - 2011 Member of the North American Spine Society section on Biologics and Basic Science. Responsible for educational content. A three year appointment. Operation Mend 2010 - present "Operation Mend," a unique partnership between Ronald Reagan UCLA Medical Center, Brooke Army Medical Center in San Antonio, Texas, and the V.A ~Greater Los Angeles Healthcare System has been established to help treat several U.S. military personnel wounded during service in Iraq and Afghanistan. Editor 2012 - present “Current Reports in Physical Medicine and Rehabilitation.” DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 50210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com COMMITTEE S College of Applied Anatomy, UCLA Member since 2003 David Geffen School of Medicine at UCLA Mentor for UCLA Medical Students Department of Orthopaedics, UCLA Member since 2003 Radiology committee Department of Pharmacology, SM-UCLA 2004 - 2006 Santa Monica Hospital Pharmacy and Therapeutics North American Spine Society Member since 2007 Section on Biologics 2008 - 2011 Department of Orthopaedics, UCLA Member since 2011 Clinic committee UCLA School of Medicine Member since 2014 Value Analysis Committee ACGME Pain Medicine Milestone Project June 2014 Board member to help create an evaluation tool of a resident pain physician in the context of their participation in ACGME accredited residency or fellowship programs in the United States. The Milestones provide a framework for the assessment of the development of the resident physician in key dimensions of the elements of physician competency in a specialty or subspecialty. They neither represent the entircty of the dimensions of the six domains of physician competency, nor are they designed to be relevant in any other context. INTERNATIONAL COURSE DIRECTOR International Musculoskeletal Society. Beirut, Lebanon July 2015/2016 Course instructor for cadaver training to Middle East Physician members. Thailand Spine Society. Bangkok, Thailand January 2016 Course director and instructor for annual national meeting - Spine section. Chinese Association of Orthopedic Surgeons (CAOS). Chengdu, China May 2016 Course instructor for cadaver training to Chinese and Asian Physician members. Indonesian Spine Society. Surabya and Bali, Indonesia September 2016 Course instructor for cadaver training to Indonesian spine members. Singapore World Congress for Lower Back and Pelvic Pain October 2016 Cadaver training course for spinal cord stimulators and intrathecal drug delivery system. DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com INTERNATIONAL COURSE DIRECTOR Egyptian Spine Society. Sharm El Sheik, Egypt November 2016 Staff lecture and moderator for spine training to Egyptian spine members World Orthopedic Innovation Summit and Expo, Shanghai, China April 2017 Course instructor for cadaver training to Chinese and Asian Orthopedic surgeon members. Chinese Association of Orthopedic Surgeons (CAOS). Guangzhu, China May 2017 Course instructor for cadaver training to Chinese and Asian Physician members. ArabSpine Course Diploma - Dubai International Spine Conference May 2017 Staff lecture and moderator for spine training to Arabic spine members PUBLICATIONS 1. Preoperative Nutritional Status and Outcome of Elective Total Hip Replacement NYMC Epidemiology and Orthopedic Departments: Clinical Orthopaedics and Related Research ~~ 326:153-161, May 1996 2. Chapter: “The Hip: Anatomy, Pathology, and Diagnosis” Physical Medicine and Rehabilitation Secrets, 2™ Edition. Editor: O’Young, B Hanley & Belfus, Inc., Philadelphia, 2002 3. Pocketpedia, Pocket Guide For Physical Medicine And Rehabilitation Choi H, Sugar R, Fish DE, et al. Lippincott, Wiliams & Wilkins; ISBN-13: 9780781744331 March 2003 4. Correlation of Standardized Testing and Other Factors with Success on the 2001 American Board of Physical Medicine and Rehabilitation Part One Board Certificate Examination. Fish DE, Radfar-Baublitz LS, Choi H, Felsenthal G American Journal of PMR; 82(9): 686-691, Sept 2003 5. Optimal Resistance Training: Comparison of DeLorme vs. Oxford Techniques Fish DE, Krabak B, Johnson-Greene D, deLateur BJ American Journal of PMR; 82(9): 686-691, Dec 2003 6. Hip Migration Percentage In Children With Cerebral Palsy Treated With Botulinum Toxin Type-A Pidcock FS, Fish DE, Johnson-Greene D, Borras | Archives of PMR; 86(3): 431-435, March 2005 PUBLICATIONS (cont’) DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com 7. Post-Lumbar Surgery Complex Regional Pain Syndrome Fish DE Pain Physician; 8:319-22, July 2005 8. Diagnostic Evaluation of Chronic Low Back Pain: Chapter 4 Low Back Pain Monograph Series Editor: Jenis LG American Academy of Orthopaedic Surgeons; 31: 37-56, 2005 9. Oswestry Disability Index Versus Neck Disability Index Scores In Lumbar And Cervical Pain Patients [Abstract] Cherie C. Cross, BS, MSII; Glenn Ozoa, DO; David E. Fish, MD, MPH, Quynh Pham, MD. Journal of Investigative Medicine, Vol. 55 (1), #162, January 2007. 10. Treatment Of Iliopsoas Tendinitis After A Left Total Hip Arthroplasty With Botulinum Toxin Type A Fish DE; Chang WS; Pain Physician.;10;565-571;2007 11. The Use Of Electromyography To Predict Functional Outcome Following Transforaminal Epidural Spinal Injections For Lumbar Radiculopathy. Fish DE, Shirazi EP, Pham Q. J Pain.; 2008 Jan;9(1):64-70. Epub 2007 Nov 5 12. The S1 "Scotty Dog": Report Of A Technique For S1 Transforaminal Epidural Steroid Injection. Fish DE, Lee PC, Marcus DB. Arch Phys Med Rehabil. 2007 Dec;88(12):1730-3. 13. Scapular Winging: Anatomical Review, Diagnosis, And Treatments Ryan M. Martin, David E. Fish Curr Rev Musculoskelet Med (2008) 1:1-11 14. Pain Precedes Computer Axial Tomography And Scintigraphic Findings In An Osteoporotic Vertebral Compression Fracture: A Case Report. Marcus DB, Lee PC, Fish DE. Pain Med. 2008 Jul 24. 15. Atypical Presentation of Osteomyelitis, Discitis, Epidural, and Iliopsoas Abscess in DISH Syndrome. Fish DE, Middleton K, Gluzman A. Am J Phys Med Rehabil. 2008 Aug PUBLICATIONS (cont’d) DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com 16. MRI Prediction Of Functional Outcome In Cervical Radiculopathy Patients Following Epidural Steroid Injection Fish DE, Kobayashi H, Chang T, Pham Q Journal of Physical Medicine and Rehabilitation 2008 Dec 23. 17. Lumbar Spondylosis: Clinical Presentation And Treatment Approaches. Middleton K, Fish DE. Curr Rev Musculoskelet Med. 2009 Jun;2(2):94-104. Epub 2009 Mar 25. 18. Evaluating Correlation of Two Pain Scales in Spinal Procedures. Fish DE, Lee PC, Parti A, Pham Q. Fed Pract. 2010;27(5):24-28 19. The Risk of Radiation Exposure to the Eyes of the Interventional Pain Physician Fish DE, Kim A, et al. Radiology Research and Practice Volume 2011, March 2011, Article ID 609537, 5 pages 20. Pain Medicine Pocketpedia Kim HS, Fish DE, Choi H Lippincott Publishing; JSBN-10: 0781772184. May 2011 21. Evaluation of the Patient with Neck Versus Shoulder Pain Fish DE, Gerstman BA, Lin V Phys Med Rehabil Clin N Am 22 (2011) 395-410 22. Thoracic Outlet Syndrome Ozoa G, Alves D, Fish DE. Phys Med Rehabil Clin N Am. 2011 Aug;22 (3):473-83 23. Spinal Epidural Injections for Lumbar Spinal Radiculopathy Pain: Chapter 71 Fish DE Advanced Reconstruction: Spine, AAOS 2011 ISBN/ISSN: 9780892035816 Page 663-666 24. Cervical Facet Arthoropathy Gerstman B, Hampton S, Fish DE Therapeutic Program For Musculoskeletal Disorders. Demos Medical Publishing 2013 25, Sacroiliac Joint Syndrome After a Rear-Ended Motor Vehicle Collision. Fish DE; Fung, D; Jones, A; Molinares, D. AAPM&R Case of the Month, MSK Case #36. January 2014 26. Iatrogenic Spinal Cord Injury Resulting From Cervical Spine Surgery. Daniels AH, Hart RA, Hilibrand AS, Fish DE, Wang JC, Lord EL, Buser Z, Tortolani PJ, Stroh DA, Nassr A, Currier BL, Sebastian AS, Arnold PM, Fehlings MG, Mroz TE, Riew KD. Global Spine J. 2017 Apr; 7(1 Suppl):84S-90S. doi: 10.1177/2192568216688188. Epub 2017 Apr I. PUBLICATIONS (cont'd) DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com 27. C5 Palsy After Cervical Spine Surgery: A Multicenter Retrospective Review of 59 Cases. Thompson SE, Smith ZA, Hsu WK, Nassr A, Mroz TE, Fish DE, Wang JC, Fehlings MG, Tannoury CA, Tannoury T, Tortolani PJ, Traynelis VC, Gokaslan Z, Hilibrand AS, Isaacs RE, Mummaneni PV, Chou D, Qureshi SA, Cho SK, Baird EO, Sasso RC, Arnold PM, Buser Z, Bydon M, Clarke MJ, De Giacomo AF, Derakhshan A, Jobse B, Lord EL, Lubelski D, Massicotte EM, Steinmetz MP, Smith GA, Pace J, Corriveau M, Lee S, Cha PI, Chatterjee D, Gee EL, Mayer EN, McBride OJ, Roe AK, Yanez MY, Stroh DA, Than KD, Riew KD. Global Spine J. 2017 Apr; 7(1 Suppl):64S-70S. doi: 10.1177/2192568216688189. Epub 2017 Apr 1. 28. Intraoperative Death During Cervical Spinal Surgery: A Retrospective Multicenter Study. Wang JC, Buser Z, Fish DE, Lord EL, Roe AK, Chatterjee D, Gee EL, Mayer EN, Yanez MY, McBride OJ, Cha PI, Arnold PM, Fehlings MG, Mroz TE, Riew KD. Global Spine J. 2017 Apr; 7(1 Suppl):127S-1318S. doi: 10.1177/2192568217694005. Epub 2017 Apr 1. 29. Epidural Hematoma Following Cervical Spine Surgery. Schroeder GD, Hilibrand AS, Arnold PM, Fish DE, Wang JC, Gum JL, Smith ZA, Hsu WK, Gokaslan ZL, Isaacs RE, Kanter AS, Mroz TE, Nassr A, Sasso RC, Fehlings MG, Buser Z, Bydon M, Cha PI, Chatterjee D, Gee EL, Lord EL, Mayer EN, McBride OJ, Nguyen EC, Roe AK, Tortolani PJ, Stroh DA, Yanez MY, Riew KD. Global Spine J. 2017 Apr; 7(1 Suppl):120S-1268S. doi: 10.1177/2192568216687754. Epub 2017 Apr 1. 30. Rare Complications of Cervical Spine Surgery: Pscudomeningocoele. Ailon T, Smith JS, Nassr A, Smith ZA, Hsu WK, Fehlings MG, Fish DE, Wang JC, Hilibrand AS, Mummaneni PV, Chou D, Sasso RC, Traynelis VC, Arnold PM, Mroz TE, Buser Z, Lord EL, Massicotte EM, Sebastian AS, Than KD, Steinmetz MP, Smith GA, Pace J, Corriveau M, Lee S, Riew KD, Shaffrey C. Global Spine J. 2017 Apr; 7(1 Suppl):109S-1148S. doi: 10.1177/2192568216687769. Epub 2017 Apr 1 RESEARCH PRESENTATIONS 1. Johns Hopkins Medical Institute, Department of Sports Medicine June 2000 Case presentation: “Groin Injury in A Gymnast” American College of Sports Medicine Conference in Indianapolis, IN 2. Johns Hopkins Medical Institute, Department of PMR, November 2000 Topic presentation: “Prevention of Hip Migration in Cerebral Palsy with Botox” Academy of PM+R National Meeting in San Francisco, CA 3. Arizona Geriatric Society: Dementia/Pain Management in the Elderly November 2001 Speaker Presentation: “Dementia Rehabilitation” Arizona Chapter of the Alzheimer Association in Tempe, AZ 4. UCLA - VAGLAHS multicampus program, Division of PMR February 2002 Paper Presentation: “Use of Morphine As It Relates To Anxiety And Depression In Low Back Pain” 8 DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com Association of Academic Physiatrists National Meeting in Las Vegas, NV 5. UCLA - VAGLAHS multicampus program, Division of PMR March 2003 Paper Presentation: “Pain Location As A Predictor of Outcome In Chronic Low Back Pain Patients Undergoing Spine Injections” Association of Academic Physiatrists National Meeting in Ft. Lauderdale, Florida. 6. UCLA - VAGLAHS multicampus program, Division of PMR October 2003 Poster Presentation: “Gabapentin Effect on Functional Outcome Following Epidural Spinal Injections For Lumbar Radiculopathy” American Academy of PMR National Meeting in Chicago, Illinois. 7. UCLA - VAGLAHS multicampus program, Division of PMR October 2003 Paper Presentation: “The Use Of Electromyography To Predict Functional Outcome Following Epidural Spinal Injections For Lumbar Radiculopathy” American Academy of PMR National Meeting in Chicago, Illinois. 8. UCLA - Dept. of Orthopaedics October 2003 Poster Presentation: “Post-Lumbar Surgery Complex Regional Pain Syndrome: A Case Report” American Academy of PMR National Meeting in Chicago, Illinois. 9. UCLA - Dept. of Orthopaedics October 2004 Poster Presentation: “Functional Outcomes for Transforaminal Epidural Injections” American Academy of PMR National Meeting in Phoenix, Arizona 10. UCLA - Dept. of Orthopaedics October 2005 Poster Presentation: “Catastrophizing Scale As A Predictor Of Functional Qutcome After Cervical Epidural Injection For Upper Extremity Radiculopathy” American Academy of PMR National Meeting in Phoenix, Arizona. 11. UCLA - Dept. of Orthopaedics October 2005 Poster Presentation: “Pain Diagrams as a Predictor of Outcome in Chronic Cervical Neck Pain Patients Undergoing Spine Injections” American Academy of PMR National Meeting in Phoenix, Arizona. 12. UCLA ~ WLA VA Department of Physical Medicine and Rehabilitation August 2006 Poster Presentation: “Case Report: Complex Regional Pain Syndrome Following Lumbar Surgery PMRS Annual Research Day Symposia, Los Angeles, California 244 13. UCLA - Dept. of Orthopaedics November 2006 Poster Presentation: “Glomus Jugulare Tumor Presenting as Neck Pain and Hoarseness: A Case Report American Academy of PMR National Meeting in Honolulu, Hawaii. 14 UCLA - Dept. of Orthopaedics November 2006 Poster Presentation: “Affective Disorder Prediction and Psychological Risk Factors By Initial Physical Examination Screening Variables In Spine Pain Patients 9 DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com American Academy of PMR National Meeting in Honolulu, Hawaii. 15 UCLA - Dept. of Orthopaedics November 2006 Poster Presentation: The Prognostic Value Of The Hospital Anxiety And Depression Scale And The Catastrophizing Scale In Functional Outcome After Epidural Steroid Injection For Low Back Pain American Academy of PMR National Meeting in Honolulu, Hawaii. 16 UCLA - Dept. of Orthopaedics November 2006 Poster Presentation: Pain Diagrams as a Predictor of Qutcome in Chronic Cervical Neck Pain Patients Undergoing Spine Injections American Academy of PMR National Meeting in Honolulu, Hawaii. 17 UCLA - Department of Orthopaedics May 2007 Poster Presentation; Functional Outcome of Patients with Lumbar Radiculopathy Using Variable Needle Positions and the Relation of Contrast Spread during Lumbar Transforaminal Epidural Spinal Injections (LTFESI). "Proceedings of ARMC Research Conference", Volume 2, Number 1, May 7-8, 2007; Page 22, poster number 27. 18. UCLA - Department of Orthopaedics October 2007 Platform Presentation: “The Biologics Of Acute And Chronic Pain, An Update” North American Spine Specialists 22" Annual meeting, Austin, Texas 19. UCLA - Department of orthopaedics November 2008 Plantform Presentation: “The Shoulder Neck Syndrome” American Academy of PMR National Meeting in San Diego, California. 20. UCLA - Department of orthopaedics November 2008 Poster Presentation: “Case Report: Atypical Presentation Of Osteomyelitis, Discitis, Epidural, And Iliopsoas Abscess In Diffuse Idiopathic ” American Academy of PMR National Meeting in San Diego, California 21. UCLA - Department of Orthopaedics November 2008 Poster Presentation: “The Effect of Needle Position and Contrast Spread Pattern on Outcome of Lumbar Transforaminal Epidural Steroid Injections ” American Academy of PMR National Meeting in San Diego, California 22. UCLA - Department of Orthopaedics February 2009 Poster Presentation: “Fellowship Training For Epidurals” Association of Academic Physiatrists National Meeting in Colorado Springs, CO 23. UCLA - Department of Orthopaedics February 2009 Poster Presentation: “Case Report: Facet Cyst Enlargement After Foraminal Epidural” Association of Academic Physiatrists National Meeting in Colorado Springs, CO 10 DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com 24. UCLA~ Department of Orthopaedics March 2009 Epidemiology of Injury in a Major Collegiate Taekwondo Tournament. 14th Annual AMSA Poster Session, Poster Presentation. Sponsored by the National Health Service Corps, National Institute of Health, and the AMSA Foundation. AMSA Annual Convention, Washington, DC, 25. UCLA - Department of Orthopaedics October 2009 Poster Presentation: Epidemiology and Mechanism of Injury in a Major Collegiate Taekwondo Tournament American Academy of PMR National Meeting in Austin, TX. 26. UCLA - Department of Orthopaedics October 2009 Poster Presentation: Catastrophizing As A Predictor Of Outcome After Cervical Epidural Injection For Upper Extremity Radiculopathy Fish DE, Ozoa G, Pham Q American Academy of PMR National Meeting in Austin, TX. 27. UCLA - Department of Orthopaedics October 2009 The Influence of Ethnicity and Gender on Back Pain Treatment Outcomes Cyril G, Fish DE, Bazargan-Hejazi S, Mukai A American Academy of PMR National Meeting in Austin, TX. 28. North American Spine Society November 2009 Pain Factors In Treatment Of Spinal Disorders Program Director and Moderator NASS National Meeting in San Fransisco, CA. 29. UCLA~ Department of Orthopaedics February 2010 Pain Perceptions in Martial Arts: Pain Levels and Epidemiology of Risk Factors Chang E, Kim W, Hsieh S, Kim E, Yee S, Kim H, Pham Q, and Fish D. American Academy of Pain Medicine’s 26" Annual Meeting, San Antonio, TX,. 11 DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com RESEARCH PRESENTATIONS (cont’d) 30. UCLA~ Department of Orthopaedics April 2010 The Role of Pain in Martial Arts: Does Pain Influence Safety In Competition? Association of Academic Physiatrists, Bonita Springs, FL. 31. North American Spine Society October 2010 Spinal Cord Stimulation In Treatment Of Spinal Disorders Program Director, Moderator, and Speaker NASS National Meeting in Orlando, Fl. 32. UCLA - Department of Orthopaedics November 2010 Poster Presentation: Fluoroscopic Guidance Time To Determine Trainee Competence American Academy of PMR National Meeting in Seattle, WA. 33. UCLA - Department of Orthopaedics November 2011 Poster Presentation: Sacroiliac Joint Pain Post MVA American Academy of PMR National Meeting in Orlando, FL. 34 UCLA - Department of Orthopaedics July 2012 Platform Presentation; Functional Outcome of Patients with Lumbar Radiculopathy Based On Contrast Spread during Lumbar Transforaminal Epidural Spinal Injections (LTFESI). International Spinal Injection Society National Meeting in Las Vegas, NV 35 UCLA - Department of Orthopaedics November 2014 Platform Presentation: “Years Best Spine Paper in Current Literature Review” American Academy of PMR National Meeting in San Diego, California. 36 UCLA - Department of Orthopaedics October 2016 Platform Presentation: “Controversial Topics Regarding Facet Interventions: Where Do We Go From Here? ” American Academy of PMR National Meeting in San Diego, California. DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com COMMUNITY PRESENTATIONS 1. UCLA - 8" Annual Primary Care Update, Las Vegas, NV “Non-operative treatment of Chronic Low Back Pain” Peer lecture for CME credit in pain medicine 2. UCLA - Suburban Medical Center, Palamino, CA “Non-operative treatment of Chronic Low Back Pain” Peer lecture for CME credit in pain medicine 3. UCLA Medical Center, Los Angeles, CA “Low back Pain evaluation and treatment” Peer lecture for CME credit in Primary Care Practice 4. Cedars-Sinai Hospital - Medical Center, Los Angeles, CA “Cervical Spine: Evaluation, Diagnosis and Treatment: CME lecture and Grand Rounds Department of Rehabilitation Medicine 5. UCLA Case Manager Update “Complex Regional Pain Syndrome: Update and Management” 6. YMCA, Los Angeles “Knee Osteoarthritis: Update and Management- Hyaluronic Acids” 7. North American Spine Society- Biologics Update “Update on Spinal Pain- Research, Treatment, Diagnoiss” National Meeting Lecture, Austin Texas 8. Cedars-Sinai Hospital - Medical Center, Los Angeles, CA “Cervical and Lumbar Spine: Evaluation, Diagnosis and Treatment:” Annual Meeting for Neurologist and NeurosurgeonsCME lecture 9. American Academy of Orthopaedic Surgeons “Natural History of Spinal Stenosis” Annual Meeting Specialty Day- North American Spine Society, San Francisco, Ca 10. North American Spine Society- Biologics Update “Update on Spinal Pain- Research, Treatment, Diagnosis” National Meeting Lecture, Toronto Canada 11. California Orthopedic Society “Epidural injection for Lumbar Radiculopathy” Annual Meeting for Orthopedic Surgeons 13 April 2003 April 2003 May 2005 July 2005 November 2006 February 2007 August 2007 February 2008 March 2008 August 2008 May 2009 DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com COMMUNITY PRESENTATIONS (cont’d) 12. Kaiser Permanente: PMR Pain Management Symposium “Post Laminectomy Pain Syndrome: Evaluation and Treatment” Annual Meeting for Kaiser Southern California Physicians 13. Kaiser Permanente: PMR Pain Management Symposium “Lumbar Myofasical Pain Syndrome: What To Do About It?” Annual Meeting for Kaiser Southern California Physicians 14. UCLA ~ Department of Orthopedics “The Diagnosis of Thoracic Outlet Syndrome” Steamboat Springs Technology Summit 15.UCLA - Department of Orthopedics January 2010 “Functional Discograms And Diagnosis Of Lumbar Disk Pain” Steamboat Springs Technology Summit 16. UCLA - Department of Orthopedics January 2010 “Update on Spinal Cord Stimulators” Steamboat Springs Technology Summit 17. UCLA - Department of Orthopedics “Spinal Cord Stimulators In The Use of Pain Syndromes” NASS National Meeting, Orlando, Fl. 18. UCLA - Department of Neurosurgery “Lumbar Spine Pain Evaluation With Non-Surgical Treatment” Grand Rounds, Department of Neurosurgery. 19. Cedar Sinai Medical Center “Sacroiliac Joint: What We Know And How We Can Treat.” 10" Annual Symposium For Spinal Disorders, Las Vegas, Nevada 20. UCLA School of Medicine, Los Angeles, CA “Lumbar Spine: Evaluation, Diagnosis and Treatment:” MEDPrime Annual Meeting for Family Practice and CME lecture. Anaheim, CA. 21. UCLA School of Medicine, Los Angeles, CA “Advances In Medical Technology Of The Spine” Annual Meeting for Neurologist and Neurosurgeons CME lecture 14 July 2009 July 2009 January 2010 October 2010 November 2010 February 2011 May 2011 June 2011 DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com 22. West LA Veterans Administration/GLA PMR August 2011 ‘Discography And Current Concepts On Disk Pain And Treatment” 23. West LA Veterans Administration/GLA Physical Medicine and Rehabilitation November 2011 ‘The Role Of The Physician In Medical-Legal Cases’ 24. UCLA School of Medicine, Los Angeles, CA May 2012 “Advances In Medical Technology For Pain” Annual Meeting for Neurologist and Neurosurgeons CME lecture 25. UCI, Irvine, CA March 2013 ‘The Role Of The Physician In Medical-Legal Cases’ ‘Billing and Coding for Physicians: Consultations and Electromyography’ Grand Rounds Presentation to UCI PMR Department and ResidencyProgram 26. American College of Spine Surgeons June 2013 ‘Diagnostic and Therapeutic Spine Injections’ National meeting faculty participant 27. American College of Spine Surgeons May 2015 ‘Updates on Cervical Spine Epidural Injections and Steroid Use’ National meeting faculty participant 28. The Gerry Spence Trial Lawyers College August 2015 Dubois, Wyoming Graduate training program I a physician medical expert presentation workshop 15 DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@email.com INTERNATIONAL PRESENTATIONS 1. International Musculoskeletal Society. Beirut, Lebanon ‘Updates for spinal cord stimulators for spine and peripheral pain syndromes’ ‘Compression fractures of the Spine. Treatment Strategies’ ‘Discography for Spine Pain. What are the Outcomes.’ ‘Sacroiliac Joint. What we know about pain and treatment’ 2. Thailand Spine Society. Bangkok, Thailand ‘Basic Work up for Spine Pain with Conservative Treatment’ ‘Injections for Determination of Pain Generators’ 3. Chinese Association of Orthopedic Surgeons (CAOS). Chengdu, China ‘Injections for Determination of Pain Generators’ Live Feed for Interlaminar and Caudal Spine Injection Techniques ‘Spinal Cord Stimulation for Chronic Pain’ 4. Indonesia Spine Society (CAOS). Surabaya and Bali Updates in Spinal Cord Stimulation Spine Surgical Planning with Spinal Injections Conservative Spine Care with Rehabilitation 5. Egyptian Spine Society. Sharm El Sheik, Egypt Radiofrequency ablation and facet targeted spinal injections Spinal Cord stimulation with lower back pain. 6. World Orthopedics Innovation Summit and Expo, Shanghai China Rehabilitation of Lumbar Spine pre and post Surgical intervention 7. Chinese Association of Orthopedic Surgeons (CAOS). Guangzhou, China Update on Implantable Pain Therapies Epidural Injections For The Treatment of Lumbar Spine Pain 8. ArabSpine Course Dubai UAE - Dubai International Spine Conference Pain Therapies in Spinal Cord Injured Patients Spinal Cord Injury treatment Update with Stem Cells Rehabilitation strategies in Spinal Cord Injured Patients Intradiscal Techniques for Lumbar Spine Pathophysiology of Pain In The Spine Physical Examination of Spine Pain 16 July 2015 January 2016 May 2016 September 2016 November 2016 April 2017 May 2017 May 2017 DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com PAIN MEDICINE FELLOWS Sean Baumshad, MD July 2002 - June 2003 Raymond Esquieres, MD July 2003 - June 2004 Sanjog Pangarkar, MD Quan Nguyen, DO July 2004 - June 2005 Jessica Bren Boston, MD Daniel Marcus, MD Jill Gorze, MD July 2005 - June 2006 Hyung Kim, MD Milena Zirovich, MD Antione Jones, MD Chun Lin, MD July 2006 - June 2007 Nathan Walters, MD Alan Chen, MD Shailesh Patel, MD Dan Alves, MD July 2007 - June 2008 Assaf Gordon, MD Jae Jung, MD Arash Lavian, MD Ai Mukai, MD July 2008 - June 2009 James Behr, MD Kevin Wang, MD Chris Janssen, MD Stephen Yoon, MD July 2009 - June 2010 Allen Chen, MD Glen Ozoa, MD Sharon Bassie, MD Beny Charcian, MD July 2010 - June 2011 Andrew Kim, DO John Pan, MD "Brett Gerstman, MD 17 DAVID ELI FISH, MD/MPH 1350 Davies Dr. Beverly Hills, Ca 90210 T: (310) 403-1347 F: (310) 860-1946 E: davidfishmd@gmail.com PAIN MEDICINE FELLOWS (Cont’d) Woojae Kim, MD July 2011 - June 2012 Nathan Perizo, DO Elite Ben-Ozer, MD Jerome Lee, MD Jason Berk, MD July 2012 - June 2013 Stephan Dechter, DO Paul Lee, MD Casey Fisher, MD Bianca Tribuzio, DO July 2013 - June 2014 Michelle Poliak, MD Daniel Rivera, MD Mark Miedema, MD Sarah O’Brien, MD July 2014 - June 2015 Nicholas Muraoka, DO Joseph Solberg, DO Jacob Lee, DO Edward Pang, MD July 2015 - June 2016 Albert Vu, MD Eric Leung, MD Brian Joves, MD Chirag Vora, DO July 2016 - June 2017 Rhadika Sood, DO Herbie Yung, MD Phuong Le, MD Gabriel Rudd-Barnard, MD July 2017 - June 2018 David Nguyen, MD Pavi Demian, DO Long Le, MD 18 EXHIBIT “2” ANATOL PODOLSKY, M.D. Fellow of American Academy of Orthopedic Surgery Education & Degrees : Undergraduate Postgraduate Undergraduate Medical School Intership @; Residency Biomechanics Iospital affiliations: Memberships & Associations: Publications : Awards : Special interests : Volunteer work : Orthopedic and Spine Surgery, Sports Medicine 400 Newport Center Dr., Suite # 601 Newport Beach, CA 92660 (949) 644-6882 Curriculum Vitae Date & place of birth: March 1952. St.Petersburg , Russia 1971-1975 Lesgaft Institute. St.Petersburg, Russia 1976 M.S. in Physiology of Sports 1981-1982 UC Irvine / no degree 1982-1986 UC Irvine Medical College / M.D 1986-1991 Mayo Clinic. Dept. of Orthopedic Surgery M.S. in Orthopedic Biomechanics, Mayo Clinic Orange Coast Memorial. Saddleback Memorial, St. Joeseph Hospital, Mission Regional Hospital, Fountain Valley Regional Hospital AAOS, American Assoc. of Hip & Knee Surgeons, Sports Medicine Committee of USFSA (US skating federation) Strength & jump height in figure skaters . American Jornal of Sports Medicine | 400-405: 1990 Biomechanical Performance of Circular Fixators CORR 293: 61-70: 1993 local Anesthesia of the Hand. 199117: 881-88 Jornal of Dermatology Oncology and Surgery Mayo Clinic Kelly Award for Excllence in Orthopedic Research. 1989. Traveling Fellowship to Curopean Orthopaedic Centers (GB, ttaly . Switzerland , Russia ) 1990, CalPers Blue Distinction Perferred Center Surgeon for Joint Replacement Surgery. 2011 Spine and Joint Replacement Surgery. Design of Orthapaedic Implants. UC Irvine Volunteer Faculty Clinical Instructor for Orthopaedic Program since 1991 to 2001 Volunteer Orthopaedic Surgery for Russian Hospitals from 1989 to present. EXHIBIT “3” Lo mea forensic Los Angeles .L. Vancouver .. Toranto STEPHANIE BONIN, PhD PE BIOMECHANICAL ENGINEER EDUCATION Doctor of Philosophy, Industrial Engineering, University of Miami, 2017. Master of Science, Mechanical Engineering, Michigan State University, 2001. Bachelor of Science, Engineering Mechanics, Michigan State University, 1997. Bachelor of Sclence, Physiology, Michigan State University, 1997. PROFESSIONAL STATUS Registered Professional Engineer, State of California, since 2017. License Number 38652. Certified Playground Safety Inspector, since 2017, Certification Number 40179-1220. Certified Child Safety Passenger Technician, Since 2018, Certification ID T781193. PROFESSIONAL ASSOCIATIONS Assaciation for the Advancement of Automotive Medicine, since 2017. American Society of Mechanical Engineers, since 2013. ASTM International FO8 ~ Sports Equipment and Facilities voting committee member, since 2015. Gait and Clinical Movement Analysis Society, since 2011. SCHOLARLY ACTIVITIES University of Kentucky, Sports Medicine Research Institute: Jockey & Equestrian Advisory Board Member PROFESSIONAL EXPERIENCE MEA FORENSIC ENGINEERS & SCIENTISTS, LAGUNA HILLS, CA Blomechanical Engineer, January 2012 to present Conducts biomechanical analyses to assess the relationship between injuries and applied forces in cases involving automobile collisions, pedestrian impacts, slip/trip and fall, and sports Injuries. Analyzes effectiveness of protective devices Including seat belts and helmets. Conducts research on motorcycle helmet response during impacts using cadaver heads and instrumented headforms. Investigates Impact performance of helmets on, above, and below the test line specified in helmet certification standards. INSTITUTE FOR MOBILITY AND LONGEVITY, JUPITER, FL Blomechanist, 2009 to 2012 Evaluated of the efficacy of the 3D Knee ® implant by coordinating, leading and reporting on a 5-year follow-up study for device manufacturer, observed surgeries and followed patients by monitoring clinical outcome measures, conducted and reported on clinical gait analyses using 3-D mation capture. PRATT & WHITNEY ~ EAST HARTFORD, CT Ergonomic and Repair Development Engineer, 2005 to 2009 Assessed operator/equipment interface, designed and Implemented manufacturing solutions to reduce ergonomic risks. Led effort to incorporate ergonomics into the design control process, collaborated across business units and technical disciplines for process improvements, conducted injury investigations, led continuous improvement initiatives, and completed 2 years of courses in Physical Therapy. Developed technical data and conducted structural analysis of turbine airfoils, conducted root cause and corrective action Investigations. DOCTOR'S RESEARCH GROUP, INC., PLYMOUTH, CT Product Development Engineer, 2001 to 2002 Developed dental devices from concept to manufacturing including design, prototyping, vendor sourcing, patent reviews, supported 510(k) and patent submissions, established assembly processes, observed surgical procedures, provided training, and integrated surgeon feedback Into designs, responded to technical inquiries. www. meaforensic.com 23281 Vista Grande Drive, Suite AT: 949 855 4632 Laguna Hills, CA 92653 877 855 5322 USA F: 949 855 3340 Curriculum Vitae of STEPHANIE BONIN MICHIGAN STATE UNIVERSITY, EAST LANSING, MI Research Assistant, 1997 to 2001 McPhail Equine Performance Center: Performed three-dimensional modeling and analysis of the equine temporomandibular joint, conducted gait analysis of performance horses including kinematic, kinetic, and electromyographic data collection. College of Veterinary Medicine, Laboratory for Comparative Orthopaedic Research: Performed finite element and photoelastic stress analysis of equine hooves in-vitro. Blomechanics Evaluation Laboratory, Department of Engineering Mechanics: Patient preparation, kinematic, kinetic, and electromyographlic data collection. Veterinary Assistant - College of Veterinary Medicine, Equine Hospital, 1999: Provided routine services to equine hospital patients, assisted with examinations, rehabilitation, and surgeries. BREED TECHNOLOGIES, STERLING HEIGHTS, MI Seat Belt and System Performance Engineer, 1997 to 1998 Modeled the biomechanical response of passengers in order to design safety restraint systems, experimentally Verified simulations, and incorporated a rear-center retractor into Chrysler 300M vehicles. EQUESTRIAN EXPERIENCE Trainer and competitor in dressage and eventing disciplines, 1990 to present. Assess saddle fit on horse and rider performance. TEACHING EXPERIENCE TEACHING ASSISTANT, MICHIGAN STATE UNIVERSITY, 1998 TO 2001 DEPARTMENT OF MECHANICAL ENGINEERING Fluid Mechanics Laboratory, Heat Transfer Laboratory DEPARTMENT OF PHYSIOLOGY Capstone Laboratory In Physiology Weekly laboratory lecture, assisted students with experiments, graded laboratory reports. PUBLICATIONS PEER-REVIEWED PUBLICATIONS Bonin SJ, Gardiner JC, Onar-Thomas A, Asfour SS, Siegmund GP (2017). The effect of motorcyde helmet fit on estimating head Impact kinematics from residual liner crush. Accident Analysis and Prevention 106, dol:10.1016/j.aap.20107.06.015 Bonin SJ, Luck JF, Bass CR, Gardiner JC, Onar-Thomas A, Asfour SS, Siegmund GP (2016). Dynamic response and residual helmet liner crush using cadaver heads and standard headforms Annals of Biomedical Engineering, doi 10.1007_s10439-016-1712-5. Kroeker SG, Bonin SJ], DeMarco AL, Good CA, Siegmund GP (2016). Age does not affect the material properties of expanded polystyrene liners in fleld-used bicycle helmets. Journal of Biomechanical Engineering 138(4), doi: 10.1115/1.4032804. Slegmund GP, Guskiewicz KM, Marshall SW, DeMarco AL, Bonin SJ} (2015). Laboratory validation of two wearable sensor systems for measuring head impact severity in football players. Annals of Biomedical Engineering, doi: 10.1007/s10439-015-1420-6. Harman MK, Bonin SJ, Leslie C, Banks SA, Hodge WA (2014). Total knee arthroplasty designed to accommodate the presence or absence of the posterior cruciate ligament. Advances in Orthopedics. Volume 2014, Article ID 178156. Siegmund GP, Gusklewicz KM, Marshall SW, DeMarco AL, Bonin S1 (2014). A headform for testing helmet and mouthguard sensors that measure head impact severity in football players. Annals of Blomedical Engineering 42(9) pp.1834-1845. forensic Curriculum Vitae of STEPHANIE BONIN Bonin SJ, Eltoukhy M, Asfour SS, Hodge WA (2012). Conversion of fused hip to total hip replacement with presurgical and postsurgical gait studies. The Journal of Arthroplasty, 27(3) pp. 493.e9-493.e12. Stambolian D, Eltoukhy M, Asfour S, Bonin S (2011) Investigation of avionics box precision placement using motion capturing and thermal imaging techniques. International Journal of Scientific and Engineering Research 2(12) pp. 1-6. Bonin SJ, Lanovaz IL, Johnston T, and Clayton HM (2007). Comparison of mandibular motion in horses chewing hay and pellets. Equine Veterinary Journal 39, pp. 258-262. Bonin SJ, Clayton HM, Lanovaz JL, Johnston T (2006). Kinematics of the equine temporomandibular joint. American Journal of Veterinary Research 67, pp. 423-428. PEER-REVIEWED CONFERENCE PROCEEDINGS Bonin SJ, DeMarco AL, Siegmund GP. The Effect of Hair and Football Helmet Fit on Headform Kinematics. International Research Council of Biomechanics of Injury Conference, Athens, Greece, September 12014. Slegmund GP, Bonin SJ, Luck JF, Bass CR. Validation of a Skin-Mounted Sensor for Measuring 1In-Vivo Head Impacts, International Research Council on Biomechanics of Injury Conference, Lyon, France, September 9-11, 2015. Stambalian DB, Asfour SS, Eltoukhy M, Bonin SJ. Avionics box precision placement in restricted space, XXIII Annual International Occupational Ergonomics and Safety Conference, Baltimore, MD, June 9-10, 2011. Ozkaramanli D, Asfour SS, Eitoukhy M, Stambolian DB, Bonin SJ. Effect of high-heeled shoes design on gait pattern, XXIII Annual International Occupational Ergonomics and Safety Conference, Baltimore, MD, June 9-10, 2011, Bonin SJ, Eltoukhy M, Asfour SS. Use of motion capturing systems in the evaluation of joint replacement surgeries, case study: total hip replacement, Eleventh International Symposium on the 3D Analysis of Human Movement, San Francisco, CA, July 14-16, 2010. Clayton HM. Bonin SJ, Johnson T, Lanovaz JL, Mullineaux DR (2003) Three-dimensional movements in the temporomandibular joint in horses chewing hay and pellets. Proceedings of the 18th Equine Nutrition and Physiology Society Symposium, Michigan State University, East Lansing, 4-7 June 2003, p. 282. ABSTRACTS/POSTERS Bonin SJ, Luck JF, Bass CR, Gardiner JC, Onar-Thomas A, Asfour SS, Siegmund GP (2014). A comparison of cadaver heads and standard headforms In helmet testing. 42nd International Workshop on Human Subjects for Blomechanical Research, San Diego, CA, November 9, 2014. Siegmund GP, Guskiewicz KM, Marshall SW, DeMarco AL, Bonin SJ (2014). Validation of head impact sensors for football. 42nd International Workshop on Human Subjects for Biomechanical Research, San Diego, CA, November 9, 2014. Bonin SJ, Luck JF, Bass CR, Gardiner JC, Onar-Thomas A, Asfour SS, Siegmund GP (2014). A comparison of cadaver heads and standard headforms in helmet testing. World Congress of Biomechanics, Boston, MA, July 6- 11, 2014. Siegmund GP, Guskiewicz KM, Marshall SW, DeMarco AL, Bonin SJ (2014). Validation of wearable sensors for measuring football head impacts. World Congress of Biomechanics, Boston, MA, July 6-11, 2014. Kroeker SG, Bonin SJ, DeMarco AL, Good CA, Slegmund GP (2014). Does age affect the impact properties of helmet foam liners? World Congress of Biomechanics, Boston, MA, July 6-11, 2014. LECTURES AND PRESENTATIONS February 24, 2018 - Assessing concussion risk: What your Blomechanical Expert should know - TBI Medlegal Conference, San Diego, CA. ¢ mea + fOrensic Curriculum Vitae of STEPHANIE BONIN November 15, 2017 - Expanded polystyrene (EPS) foam density varies within and between bicycle helmets - ASTM International Standards Development Meeting of Committee FO8 - Sports Equipment and Facilities, Atlanta, GA. November 13, 2014 - A Comparison of Cadaver Heads and Standard Headforms in Helmet Testing -~ ASTM International Standards Development Meeting of Committee FO8 ~ Sports Equipment and Facilities, New Orleans, LA. November 9, 2014 - A Comparison of Cadaver Heads and Standard Headforms in Helmet Testing - 42nd International Workshop on Human Subjects for Biomechanical Research, San Diego, CA. TRAINING AND PROFESSIONAL DEVELOPMENT September 26-29, 2018 - NHTSA National Standardized Child Passenger Safety Training, Pomona, CA. September 12-14, 2018 - International Research Council on Biomechanics of Injury Conference, Athens, Greece. November 15-17, 2017 - ASTM International Standards Development Meeting of Committee FO8 ~ Sports Equipment and Facilities, Atlanta, GA. November 7-8, 2017 ~ Playground Safety Inspector Certification Course, Riverside, CA. September 14-16, 2016 - International Research Council on Biomechanics of Injury Conference, Malaga, Spain. September 13, 2016 - International Research Council on Biomechanics of Injury Workshop on Crash Reconstruction, Malaga, Spain. May 3-4, 2016 - ASTM International Standards Development Meeting of Committee FO8 ~ Sports Equipment and Facllities, San Antonio, TX. July 6, 2015 ~ Building Code Overview, Ontario Society of Professional Engineers, Mississauga, ON. November 18-19, 2015 - ASTM International Standards Development Meeting of Committee FO8 ~ Sports Equipment and Facilities, Tampa, FL. November 9-11, 2015 - 59th Stapp Car Crash Conference, New Orleans, LA. November 8, 2015 - 43 International Workshop on Human Subjects for Biomechanical Research, New Orleans, LA. September 9-11 - International Research Council on Biomechanics of Injury Conference, Lyon, France. May 20-21, 2015 - ASTM International Standards Development Meeting of Committee FO8 - Sports Equipment and Facllities, Anaheim, CA. November 13, 2014 - ASTM Standards Development Meeting of Committee FO8 -- Sports Equipment and Facilities, New Orleans, LA. November 10-12, 2014 ~ 58th Stapp Car Crash Conference, San Diego, CA. November 9, 2014 ~ 42nd International Workshop on Human Subjects for Biomechanical Research, San Diego, CA. July 6-9, 2014 - 7th World Congress of Biomechanics, Boston, MA. June 9-10, 2014 ~ Commanding Presence Workshop, Toronto, ON. November 13-15, 2013 -- ASTM International Standards Development Meeting of Committee FO8 ~- Sports Equipment and Facilities, Jacksonville, FL. November 11-13, 2013 ~ 57" Stapp Car Crash Conference, Orlando, FL. November 10, 2013 - 41% International Workshop on Human Subjects for Biomechanical Research, Orlando, FL. June 26-29, 2013 - ASME Summer Bioengineering Conference, Sunriver, OR. November 14-16, 2012 - ASTM International Standards Development Meeting of Committee FO8 - Sports Equipment and Facilities, Atlanta, GA. Ls forénsic Curriculum Vitae of STEPHANIE BONIN November 13, 2012 - ASTM International Symposium on the Mechanism of Concussion in Sports, Atlanta, GA. January 7-8, 2012 ~ National Academy of Forensic Engineers bi-annual meeting, Miami, FL. November 15-17, 2011 - MADYMO Introductory Course, Livonia, MI. April 26-29, 2011 - Gait and Clinical Movement Analysis Society Annual Meeting, Bethesda, MD. August 5-9, 2008 ~ North American Congress on Blomechanics, Ann Arbor, MI. May 28-31, 2008 - Clinical Gain Analysis: A Focus on Interpretation. Connecticut Children’s Medical Center, Hartford, Connecticut. Mach 19-22, 2006 - 52M Annual Meeting of the Orthopaedic Research Society, Chicago, IL. *10/9/18 os forensic OO 0 NN A wn B W N m N O N N N N N N N O N em m d p m p m e m ee d pe e e t pe C O N N W n B A R W O N = O D Y E W N D = O PROOF OF SERVICE STATE OF CALIFORNIA ) ) SS COUNTY OF ORANGE) I am employed in the County of Orange, State of California. I am over the age of 18 and not a party to the within action, my business address is 2731 % E Coast Hwy, Corona Del Mar, CA 92625. On October 22, 2018, I served the foregoing document(s): PLAINTIFE’S DESIGNATION OF EXPERT WITNESSES on the interested parties in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Marlon C. Wadlington Attorney for Defendants Atkinson, Anderson, Loya, Ruud & Romo 12800 Center Court Dr South, Set 300 Cerritos, CA 90703 mwadlington@aalrr.com Jeffrey S. Dawson Co-Counsel for Plaintiff Law Offices of Jeffrey S. Dawson 9841 Irvine Center Drive, Suite 210 Irvine, California 92618 jeff@pi-attorney.com [X] Iam readily familiar with the firm’s practice of collecting and processing of documents and correspondence for mailing with the United States Postal Service. Under that practice, on the above date, the envelope was sealed and placed for collection and mailing following the ordinary business practices of our office. This results in the envelope being delivered to the United State Postal Service that same day, with postage thereon fully prepaid. [X] 1deposited each such envelope in the mail at Corona Del Mar, CA, with postage thereon fully paid. [ 1 Icertify that the above-referenced document(s) were served electronically on the parties listed herein at their most recent known email address or email of record by submitting an electronic version of the document(s) to One Legal, LLC, through the user interface at www.onelegal.com (designated electronic filing service provider). [ 1 Isentthe above-referenced document(s) via email to the above address. [X] 1declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on October 22, 2018, Corona Del Mar, CA. Anna E. Caludac PROOF OF SERVICE -1- EXHIBIT “2” A T K I N S O N , A N D E L S O N , L o Y A , Ru ub p & R o m o Fa x: ( 5 6 2 ) 6 5 3 - 3 3 3 3 A T T O R N E Y S AT L A W 1 2 8 0 0 C E N T E R C O U R T D R I V E S O U T H , S U I T E 3 0 0 C E R R I T O S , C A L I F O R N I A 3 0 7 0 3 - 3 3 6 4 Te ce rP HO NE : (5 62 ) 6 5 3 - 3 2 0 0 A P R O F E S S I O N A L C O R P O R A T I O N 006148.00030 217371751 ATKINSON, ANDELSON, LOYA, RUUD & ROMO A Professional Corporation Marlon C Wadlington, State Bar No. 192138 MWadlington@aalrr.com 12800 Center Court Drive South, Suite 300 Cerritos, California 90703-9364 Telephone: (562) 653-3200 Fax: (562) 653-3333 Attorneys for Defendant FULLERTON JOINT UNION HIGH SCHOOL DISTRICT SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE - CENTRAL JUSTICE CENTER DAVID TALPOS, by and through his Guardian Case No. 30-2016-00867178-CU-PO-CJC ad Litem, IOANA SIMONA TALPOS, FULLERTON JOINT UNION HIGH Plaintiff, SCHOOL DISTRICT’S DESIGNATION OF EXPERT WITNESSES Vv. FULLERTON JOINT UNION HIGH SCHOOL Complaint Filed: August 2, 2016 DISTRICT, LA SIERRA HIGH SCHOOL, Trial Date: December 10, 2018 ENDEAVOR HIGH SCHOOL, and DOES 1 Dept.: C25 through 100, inclusive, Defendants. TO ALL PARTIES HEREIN AND TO THEIR RESPECTIVE ATTORNEYS OF RECORD: Defendant Fullerton Joint Union High School District (“District”) hereby designates the following expert witness to testify at the time of trial in this matter pursuant to California Code of Civil Procedure § 2034.260: RETAINED 1. Kendall S. Wagner, M.D. 1460 N. Harbor Blvd., Ste. 100 Fullerton, CA 92835 FULLERTON JOINT UNION HIGH SCHOOL DISTRICT'S DESIGNATION OF EXPERT WITNESSES A T K I N S O N , A N D E L S O N , L o Y A , R u u p & R o m o A T T O R N E Y S AT L A W 1 2 8 0 0 C E N T E R C O U R T D R I V E S O U T H , S U I T E 31 00 C E R R I T O S , C A L I F O R N I A 9 0 7 0 3 - 9 3 6 4 T E L E P H O N E : (5 62 ) 6 5 3 - 3 2 0 0 A P R O F E S S I O N A L C O R P O R A T I O N Fa x: ( 5 6 2 ) 6 5 3 - 3 3 1 3 fe n] 0 0 ~ aN Wn EA N Ww No - - e m me m b b e d e t e t ee n pe \O co ~3 a wn RE N Ww NS ] - 20 006148.00030 217371751 Any and all experts not previously designated by the District that are designated by any other party to this action who have been deposed pursuant to California Code of Civil Procedure section 2034.410, et seq. The District may call any or all of Plaintiff's treating physicians, therapists and any and all other healthcare professionals who, although they may be percipient witnesses and have not been formerly retained as experts, may also be asked to render expert testimony. These individuals may be asked to testify concerning any and all aspects of the case including the issues of standard of care, liability, causation and damages. Any non-previously designated expert called as a rebuttal witness to testify to the falsity or non-existence of any fact used as the foundation for any expert opinion by any witness called by any other party at the time of trial. Dated: October 22, 2018 ATKINSON, ANDELSON, LOYA, RUUD & ROMO By: 4 mt SE Marlon C Wadlington Attorneys for Defendant FULLERTON JOINT UNION HIGH SCHOOL DISTRICT S92. FULLERTON JOINT UNION HIGH SCHOOL DISTRICT'S DESIGNATION OF EXPERT WITNESSES A T K I N S O N , A N D E L S O N , Lo yA a, R u u b p & R o m o A P R O F E S S I O N A L C O R P O R A T I O N A T T O R N E Y S AT L A W : 1 2 8 0 0 C E N T E R C O U R T D R I V E S O U T H , S U I T E 3 0 0 C E R R I T O S , C A L I F O A N I A 3 0 7 0 3 - 9 3 6 4 T E L E P H O N E : ( 5 6 2 ) 6 5 3 - 3 2 0 0 Fa x: ( 5 6 2 ) 6 5 3 - 3 3 3 3 _ 006148.00030 217371751 10 11 12 13 14 15 16 - 17 18 19 20 21 22 23 24 25 26 27 DECLARATION OF MARLON C. WADLINGTON I, Marlon C. Wadlington state and declare as follows: I. I'am an attorney at law duly admitted to practice before this Court and am a Partner with the firm of Atkinson, Andelson, Loya, Ruud & Romo, attorneys for Defendant Fullerton Joint Union High School District (“District”) in the above-referenced matter. 1 make this Declaration in support of the above-captioned Designation of Expert Witnesses. If called upon to do so, I could and would competently testify to the facts set forth herein of my own personal knowledge. 2. Accompanying this Declaration is a list of the persons whose expert opinion testimony the District intends to offer at trial in this action, either orally or by deposition testimony. 3. Kendall S. Wagner, M.D. (a) Attached to this Declaration as Exhibit “A” is Dr. Wagner's Curriculum Vitae, which sets forth his professional qualifications. I am informed and believe and thereon state that Dr. Wagner is a medical doctor and expert in orthopedic medicine. I am further informed and believe and thereon state that his qualifications in this field are as detailed in Exhibit “A.” (b) Dr. Wagner has agreed to testify as an expert witness at the trial in this matter. He is expected to offer testimony regarding his orthopedic physical examination of Plaintiff. He is going to offer testimony regarding the extent of Plaintiff's injuries and causation. Dr. Wagner is also expected to testify in rebuttal to any expert testimony regarding causation and the extent of Plaintiff's injuries. (c) Dr. Wagner will be sufficiently familiar with the pending action to submit to a meaningful oral deposition concerning this testimony, including his expert opinions and the bases for his expert opinions. (d) Dr. Wagner’s fee for providing deposition and trial testimony is $1,000.00 per hour. A true and correct copy of Mr. Wagner’s fee schedule is attached hereto as Exhibit “B” o1- FULLERTON JOINT UNION HIGH SCHOOL DISTRICT'S DESIGNATION OF EXPERT WITNESSES A T K I N S O N , A N D E L S O N , L O Y A , R u u p & R o m o 1 I declare under penalty of perjury under the laws of the State of California that the forgoing 2 || is true and correct. wa Executed on October 22, 2018, at Cerritos, California. L a MARLON C. WADLINGTON, Therlarant ~~ 10 11 12 13 14 15 A P R O F E S S I O N A L C O R P O R A T I O N A T T O R N E Y S AT L A W 1 2 6 0 0 C E N T E R C O U R T D R I V E S O U T H , S U I T E 3 0 0 T e L e P H O N E : ( 5 6 2 ) 6 5 3 - 3 2 0 0 Fa x. ( 5 6 2 ) 6 5 3 - 3 3 3 3 16 C E R R I T O S . C A L I F O R N I A 9 0 7 0 3 - 9 1 3 6 4 17 18 19 20 21 22 23 24 25 26 27 28 -2- Sol FULLERTON JOINT UNION HIGH SCHOOL DISTRICT'S DESIGNATION OF EXPERT WITNESSES EXHIBIT A CURRICULUM VITAE KENDALL S. WAGNER, M.D. 1460 N. HARBOR BLVD., SUITE 100 FULLERTON, CALIFORNIA 92835 657-217-5400 FAX: 657-217-5441 EDUCATION: High School U.S. Grant Fi College: University of Cali Sznta Barbera, Cali Bachelor of Arts Graduate Scheol: University of Sco. California Los Angeles, California Master of Science ~ Pnysiology September 1970 - June 197¢ x ~ C Y n C To 0 0 ; Medical School: 1 =i 5 I TO reilowshons: wo 0 EE AT Chief of M Department of Medical Cente a h 1 C Q 3 0 fy le t 0) C r= on [= i J L I E T E Te li During th ; root § Terr, ; Wagne ; Chang ; Conta : Exper ; Defcr ; Rel } jo ie > 3 fa ~ "i Tin Sar , A., Wagner, . Resnick, C.T. The Role of Suktaler Motion and Ankle i Contact Pressure Changes from { Angelar Deformities of the Tibia : Foct Ankle 7: 290, 1887 12 as R R EXHIBIT B KENDALL S. WAGNER, M.D. MED-LEGAL FEES REVIEW OF MEDICAL RECORDS § 500.06 PERHOUR ATTORNEY CONFERENCE S$ 500.00 PERHGUR ATTORNEY DEPOSITION $1,000,060 PER HOUR ] IME RETAINER FEE 8 2,500.09 COURT APPEARANCE $5,000.00 PER HALF DAY COURT APPEARANCE © $10,000.06 PER ENTIRE DAY ATTORNEY REPORT $1,000.00 PAID IN ADVANCE A T K I N S O N , A N D E L S O N , L o Y A , R u u D & R o m o 1 PROOF OF SERVICE 2 [FRCP 5(B)]J(CODE CIV. PROC. § 1013A(3)) 3 | STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 4 Tam employed in the County of Los Angeles, State of California. I am over the age of 18 years and am not a party to the within action; my business address is 12800 Center Court Drive 5 | South, Suite 300, Cerritos, California 90703-9364. 6 On October 22, 2018, I served the following document(s) described as FULLERTON JOINT UNION HIGH SCHOOL DISTRICT'S DESIGNATION OF EXPERT WITNESSES 7 | on the interested parties in this action by placing a true copy thereof erfclpsed | in sealed envelopes : addressed as follows: Jeffrey S. Dawson Attorneys for Plaintiff DAVID TALPOS, by 9 | Law Office of Jeffrey S. Dawson and through his Guardian ad Litem, [OANA 2 9841 Irvine Center Drive, Suite 210 SIMONA TALPOS Irvine, CA 92618 (949) 861-2191 11 | Fax (949) 861-2190 jeffl@pi-attorney.com Lf 12 Attorneys for Plaintiff DAVID TALPOS, by 5 aag Bradley P. Knypstra and through his Guardian ad Litem, [OANA £32272 13 | KNYPSTRA HERMES LLP SIMONA TALPOS £34857 2731 % E Coast Hwy 8<£:5% 14 | Corona Del Mar, CA 92625 $9923 (949) 432-3802 283297 15 | Fax:(949) 432-3803 i< pa 2x brad@khtriallawvers.com E S22 16 < 88" | M BY MAIL: I deposited such envelope in the mail at Cerritos, California. The 8 17 envelope(s) was mailed with postage thereon fully prepaid. I am readily familiar with - the firm's practice of collection and processing correspondence for mailing. It is 18 deposited with U.S. postal service on that same day in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if postal 19 cancellation date or postage meter date is more than one day after date of deposit for mailing an affidavit. 20 0 BY PERSONAL SERVICE: I placed the above document in a sealed envelope. 1 21 caused said envelope to be handed to our messenger service to be delivered by hand to the above address(es). 22 23 I declare under penalty of perjury under the laws of the State of California that the a foregoing is true and correct. xs Executed on October 22, 2018, at Cerritos, California. / Y 26 2 AVE) an 7 MoTissa &. fel 27 28 by FULLERTON JOINT UNION HIGH SCHOOL DISTRICT'S DESIGNATION OF EXPERT WITNESSES EXHIBIT “3” AT KI NS ON , AN DE LS ON , Lo YA , RU UD & Ro mo A7 35 80 ¢# A P R O F E S S I O N A L C O R P O R A T I O N i A T T O R N E Y S AT L A W 1 2 8 0 0 C E N T E R C O U R T D R I V E S O U T H , S I T E 3 0 0 C E R R I T O S , C A L I F O R N I A 9 0 7 0 3 - 9 3 6 4 T E L E P H O N E : (5 62 ) 6 5 3 - 3 2 0 0 Fa x: ( 5 6 2 ) 6 5 3 - 3 3 3 3 006148.00030 220415081 SOS O e Y Y A W N 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 vg, AR Rio 7/4 Ce O50 ae Sl Hy “onduiii Ory ATKINSON, ANDELSON, LOYA, RUUD & ROMO Sp, Oy 2 re Nig A Professional Corporation 5 Yap, hy Marlon C Wadlington, State Bar No. 192138 k. J,
