Motion_in_limine_1_to_preclude_nitin_bhatia_from_testifying_at_trial_MotionCal. Super. - 4th Dist.February 28, 2018© 0 ~N Oo a ~ O N = N N N N DD NM NN N D = oO @ @@ 2 oa a2 =a = = 0 ~N O O O A W N =2 O O WW 00 ~N 6 O0 0 AA O N = O Kevin R. Jolly, State Bar No. 172328 Leah Berry, State Bar No. 196505 JOLLY BERRY LAW 27762 Vista Del Lago, Suite A-11 Mission Viejo, CA 92626 E-Mail: kj@jollyberrylaw.com Phone: (949) 515-9000 Fax No.: (949) 415-2342 Attorneys for Plaintiff: Sayedeh Sahba Amjadi SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF ORANGE — CENTRAL JUSTICE CENTER Case No: 30-2018-00976542-CU-PA-CJC [Consolidated w/ Case No. 30-2018- 00978077-CU-PA-CJC] SAYEDEH SAHBA AMJADI, UNLIMITED Plaintiff, ASSIGNED FOR ALL PURPOSES TO: HON. DEREK W. HUNT Vv. Dept: C23 JERROD WEST BROWN; MARK HOWERTON; SCOTT MATTHEW Date Action Filed: February 28, 2018 MCMASTERS; and DOES 1 through Trial Date: January 27, 2020 20, inclusive, PLAINTIFF'S MOTION IN LIMINE #1 TO PRECLUDE NITIN BHATIA FROM TESTIFYING AT TRIAL Defendants. N t ” a ” “ a ” “S e” “ sa t” “ ai t? “ sa ” “s aa n? “ vg a “e at “ sa ns “o tt ? “i t? “t t? “e tt ? “v at ? TO DEFENDANT JERROD WEST BROWN AND HIS ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that PLAINTIFF Sayedeh Sabha Amjadi hereby moves he Court in limine for an order precluding defendant Jerrod West brown from calling Nitin Bhatia, M.D. from testifying at trial pursuant to Code of Civil Procedure sections 2025.220, 2034.410, and 2034.415 for failing to produce any documents identified in the notices of deposition prior to the deposition. mn 1 -1- PLAINTIFF'S MOTION IN LIMINE #1 TO PRECLUDE NITIN BHATIA FROM TESTIFYING AT TRIAL Ww 0 ~N O O OO A W N = N N N N N N NN DMN N D D N = @Q 2 DO = =a a =a a2 2 © ~N 6 O A W O N 2 O0 0 © 0 N O 6 hh W N = O° 1. INTRODUCTION On April 9, 2016 at approximately 1:43 a.m. this three-vehicle accident occurred on the southbound 55 Freeway near the Warner exit. At the time of the collision, defendant Jerrod West Brown was intoxicated and was traveling at a high rate of speed. One witness estimated his speed at approximately 95 MPH. Due to his intoxication and high rate of speed, he slammed into two other vehicles. One of the vehicles was driven by plaintiff Sayedeh Sabha Amjadi, who had a passenger (Shabnam Shahrokshahi). The other vehicle was driven by Scott McMasters. Ms. Amjadi and Ms. Shahrokshahi were taken by ambulance from the scene. Defendant Brown was arrested on suspicion of driving under the influence. On April 12, 2016 defendant Brown pied Guilty of violating California Vehicle Code sections 23153 (a) and (B), which contained an admission that he caused bodily injury to Ms. Amjadi and Mr. McMasters. He also admitted that his blood alcohol level was .16. Plaintiff Amjadi has filed this suit for recovery for personal injuries sustained in the accident. On December 9, 2019 defendant Brown served a Code of Civil Procedure section 2034 Expert Witness Designation naming Nitin Bhatia, M.D. as his only retained expert. (See Exhibit A.) The designation was received by Jolly Berry Law on December 11, 2019. On December 12, 2019 plaintiff served a Notice of Expert Deposition of Nitin Bhatia, M.D. with a request for production of documents. (See Exhibit B.) The notice set the deposition for January 2, 2020 at 10:00 a.m. The notice further cited to Code of Civil Procedure sections requiring production of Dr. Bhatia’s entire file at least three days before his deposition. Defendant's counsel claimed unavailability of Dr. Bhatia and the parties agreed to a January 16, 2020 deposition at 9:00 a.m. at Dr. Bhatia's office. An Amended Notice of Deposition of Dr. Bhatia with the same document production demands was served on defense counsel. (See Exhibit C.) Prior to January 16, 2020 at 9:00 a.m., none of Dr. Bhatia's records were produced to plaintiff's counsel. -2- PLAINTIFF'S MOTION IN LIMINE #1 TO PRECLUDE NITIN BHATIA FROM TESTIFYING AT TRIAL Ww © ~N oO 0 A W N = N N N N N N N N D R N 2 22 OS a2 a a A a 2 a ® N O O A B O N 2 0 © 0 N O G Rs W N = O 2. AUTHORITY Pursuant to Code of Civil Procedure section 2034.410: "On receipt of an expert witness list from a party, any other party may take t he deposition of any person on the list. ... " As noted above, plaintiff served a Notice of Deposition with document production demands on December 12, 2019. Thus, defendant knew that they would need to produce Dr. Bhatia's file at least three days before the deposition no later than December 17, 2019. Code of Civil Procedure section 2034.415 states: “An expert described in subdivision (b) of Section 2034.210 whose deposition is noticed pursuant to Section 2025.220 shall, no later than three business days before his or her deposition, produce any materials or category of materials, including any electronically stored information, called for by the deposition notice." Defendant and Dr. Bhatia had a legal obligation to produce all of Dr. Bhatia's records no later than January 13, 2020. However, no records were produced prior to the deposition and plaintiff's counsel was presented with new reports and information during the deposition that plaintiffs counsel had a right to review at least three days prior to the deposition. The language in Section 2034.415 utilizes the term “shall” produce. Thus, it is mandatory language and should subject the non-complaint expert to preclusion from testifying at trial. nn nn Bs PLAINTIEF'S MOTION IN LIMINE #1 TO PRECLUDE NITIN BHATIA FROM TESTIFYING AT TRIAL Ww 00 ~N oo ua A O N = N O N N N R R ND NM N B N 2 2 2 2 a2 a a a =a 2 ® ~N © A O N = O O © © N o o a »~ W N = O 3. CONCLUSION Whereas defense counsel and Dr. Bhatia had at least 27 days to timely comply with Code of Civil Procedure section 2034.415, and yet, failed/refused to do so, Dr. Bhatia should be precluded from testifying at trial as a matter of law. Defendant and his counsel should not be allowed to benefit from playing hide the ball and refusing to comply with the provisions of the Code of Civil Procedure. DATED: January 20, 2020 JOLLY BERRY LAW Sy par K i on Kevin 5 Jolly, Esq. ry Leah Berry, Esq. 4 Attorney for Plaintiff Sayedeh Sahba Amjadi -4- PLAINTIFF'S MOTION IN LIMINE #1 TO PRECLUDE NITIN BHATIA FROM TESTIFYING AT TRIAL EXHIBIT A RICHARD S. GOWER, ESQ. - Bar No. 145211 INGLIS & GOWER, LLP 500 South Grand Avenue, Suite 1400 Los Angeles, CA 90071 Phone: (213) 627-6800 Fax: (213) 622-2857 Attorney for Defendant JERROD WEST BROWN SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE — CENTRAL JUSTICE CENTER CASE NO.: 30-2018-00976542-CU-PA-CJC SAYEDEH SAHBA AMJAD], an individual, ) ) Flamit, , DEFENDANT BROWN'’S EXPERT vs ) DESIGNATION; DECLARATION OF ’ ) RICHARD S. GOWER, ESQ. JERROD WEST BROWN, MARK ) HOWERTON, an individual; SCOTT ) MATTHEW MCMASTERS, and DOES 1 to 50, ) Inclusive, ) ) Defendants. ) ) Defendant Jerrod Brown hereby submits the following list of expert witnesses who defendant expects to testify on behalf of defendant at the trial of this matter: RETAINED EXPERTS 1. Nitin N. Bhatia, M.D., 525 E. Seaside Way, Ste. 101A, Long Beach, CA 90802, (562) 436-8600. NON-RETAINED EXPERTS 1. David Greenberg, D.C., 275 Victoria Street, Suite 2A, Costa Mesa, CA 92627. 2. Kevin Trinth, M.D., Orange County Pain Specialists, 455 Old Newport Blvd., Suite 10! Newport Beach, CA 92663. (949) 933-7012. DEFENDANT’S EXPERT DESIGNATION 3. Sonny Rubin, M.D., Orange County Pain Specialists, 455 Old Newport Blvd., Suite 101, Newport Beach, CA 92663, (949) 933-7012. 4. Bijan Zardouz, M.D., Newport Care Medical Group, 3300 West Coast Highway, Suite A Newport Beach, CA 92663. 5. Christopher Brown, CRNA, Inc., 34521 Via Catalina, Unit B, Capistrano Beach, CA 9 10 14 15 16 17 92624. 6. Kasra Rowshan, M.D., Newport Care Medical Group, 3300 West Coast Highway, Suite A, Newport Beach, CA 92663. 7. Dr. Nelson Flores, Psychological Assessment Services, 2107 N Broadway Ste. 207 Santa Ana, CA 92706. 8. Maryam Rahimi, D.O., Orange County Pain & Rehab, 3300 West Coast Highway, Newport Beach, CA 92663. 9. George Mednik, Ph.D, M.D.,Precise Imaging, 6710 Kester Ave, Suite 126, Van Nuys, CA 91405, (818) 907-7723. 10. Elliot Wagner, M.D.,West Valley MR], 20251 Ventura Blvd., Suite D, Woodland Hills, CA 91364, (818) 712-0021. 11. Subin M. Dah, D.C., Lac., Southern California Health Center, 10 Corporate Park, Suite 230, Irvine, CA 92606, (949) 679-3734. 12 Jong Hun Han, L.Ac., J Acupuncture, 11752 Garden Grove Blvd., Garden Grove, CA 92843, (714) 534-0603. 13. Defendant expects to call doctors, physicians, nurses and other medical personnel from facilities who have been identified by the plaintiff as plaintiff's treating doctors, physicians, nurses, and other personnel from facilities who have not been retained as experts pursuant to Code of Civil Procedure section 2034.210, but who are experts in their field of specialty and may be asked opinion questions in addition to questions regarding their treatment. Such experts’ opinions are expected to include, but are not limited to, the following matters: extent of treatment; extent of injuries; relation of injuries to the incident; and related matters. 2 DEFENDANT'S EXPERT DESIGNATION 14. All experts designated by any other party to this action. 15. Experts who may be called for impeachment purposes pursuant to California Code of Civil Procedure section 2034.310. 4 16. Experts who may be substituted for any experts on the foregoing lists who subsequently 5 | become unavailable. 6 17. Defendant reserves the right to retain and call such experts as may become necessary or appropriate and as permitted by the provisions of Code of Civil Procedure section 2034. Defendant further reserves the right to call any and all parties and their employees or any in-house expert witnesses in this matter as well as the expert witnesses selected by plaintiff, or to read the deposition of any and all said witnesses who have testified, and elicit from said witnesses any and all expert opinions and testimony that they may be competent to give. 18. Defendant reserves the right to call in rebuttal any expert witness on issues which have not been disclosed by discovery to date. pate: 4 (1 RICHARD S-GOWER Attorney for Defendant JERROD WEST BROWN 3 DEFENDANT'S EXPERT DESIGNATION DECLARATION OF RICHARD S. GOWER I, Richard S. Gower, declare: 1. Iam an attorney at law duly licensed to practice before all of the courts of the State of California. I am a partner in the law firm of Inglis, Gower, LLP, attomeys of record for defendant Jerrod 3 || West Brown. As such, I have personal knowledge of the facts stated herein and could competently 6 || testify to those facts if called upon. 7 2. This declaration is offered pursuant to Code of Civil Procedure section 2034.260. 8 || NITIN BHATIA, M.D., F.A.C.S. 9 1. A brief statement of the qualifications of Dr. Bhatia is set forth in his curriculum vitae, which 10 || is attached as Exhibit “A.” I 2. The general substance of the testimony that Dr. Bhatia is expected to give at trial will be with 12 || regard to his findings and conclusions regarding the injuries plaintiff relates to the incident at issue in 13 || this lawsuit, his examination of plaintiff, and his review of plaintiff's medical records. A copy of Dr. t4 || Bhatia’s IME report is attached as Exhibit “B.” 15 3. Dr. Bhatia has agreed to testify at trial, 16 4. Dr. Bhatia will be sufficiently familiar with the pending action to submit to a meaningful 17 || deposition concerning his specific testimony, including any opinion and its basis that he is expected to 18 || give at trial. 19 5. Dr. Bhatia’s rate for providing deposition will be provided upon receipt. 20 21 Executed this 5 day of December, 2019, at Los Angeles, California. 22 23 24 Richard S. Gower, Declarant 25 26 I 28 4 DEFENDANT'S EXPERT DESIGNATION PROOF OF SERVICE C.C.P. Section 1011; 1013a(1) & (3) STATE OF CALIFORNIA, COUNTY OF LOS ANGELES eighteen years and not a party to the within action or proceeding; my business address is 500 S. Gran I'am a resident of the United States and employed in the County of Los Angeles, over the age : Avenue, Suite 1400, Los Angeles, California 90071 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 26 27 28 On December 9, 2019, I served the foregoing documents described a DEFENDANT BROWN? EXPERT DESIGNATION; DECLARATION OF RICHARD S. GOWER, ESQ., on all interest parties in this action by placing true and correct copies thereof enclosed in sealed envelopes addressed follows: Leah Berry, Esq. Mark S. Levine, Esq. JOLLY BERRY LAW FORD WALKER HAGGERTY & BEHAR 27762 Vista del Lago, Suite A-11 One World Trade Center, 27th Floor Mission Viejo, CA 92692 Long Beach, California 90831-2700 Telephone: (949) 515-9000 Telephone: (562) 983-2500 Facsimile: (949) 415-2342 Attorneys for Defendant, MARK HOWERTON Attorney for Plaintiff, SAYEDEH SAHBA Email: mlevine@fwhb.com AMJADI Email: leah@jollyberryvlaw.com [X] BY MAIL: I am "readily familiar" with the firm's practice of collection and processin correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service o that same day with postage thereon fully prepaid at Los Angeles, California in the ordinary course o business. Iam aware that on motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more than one (1) day after date of deposit for mailing in affidavit. [1] BY PERSONAL DELIVERY: I caused each envelope to be hand-delivered to each addressee leaving said envelope with either the addressee directly or another person at that address authorized ta accept service on the addressee's behalf. [] ELECTRONIC MAIL: By transmitting the document listed above to the email addresses listed above. SEE Rema ’ I declare under penalty of perjury under the laws of the State of Qalifornia that the above is true and correct. Executed on December 9, 2019, at Los i Tamdra Richardson PROOF OF SERVICE EXHIBIT “A” dD ) NITIN N. BHATIA, M.D, F.A.C.S. * DIPLOMATE, AMERICAN BOARD OF ORTHOPAEDIC SURGERY 525 E. Seaside Way, Ste. 101A Long Beach, CA 90802 Tel. (562) 436-8600 / Fax. (562) 436-8608 --————— CURRENT POSITION: Chief, Orthopaedic Spine Service ‘Co-Director, Comprehensive Spine Program Director, Spinal Services, The Orthopaedic and Sports Medicine Center University of California, Irvine Residency Program Director Associate Professor of Clinical Orthopaedics Department of Orthopaedic Surgery University of Califomia, Irvine EDUCATION: Stanford University, Stanford, California Bachelor of Science in Biology, 1990-1994 Graduation with Honors Baylor College of Medicine, Houston, Texas Doctor of Medicine with Highest Honors, 1994-1998 AOA, Elected Junior Year Michael E. DeBakey Scholar Award Class Valedictorian University of California, Los Angeles General Surgery Internship, 1998 - 1999 Orthopaedic Surgery Residency, 1999 - 2003 University of Miami, Jackson Memorial Medical Center, Miami, Florida Combined Orthopaedic and Neurosurgical Spinal Surgery Fellowship (Dr. Frank J. Eismont, Director) July, 2003 — June, 2004 Miami Children’s Hospital, Miami, Florida Spinal Deformity Fellowship (Dr. Harry L. Shufflebarger, Director) June, 2004 — August, 2004 A @ | D AWARDS AND HONORS: Stanford University, Kappa Alpha Order Scholarship Award, 1993 Stanford University, Graduation with Honors, 1994 The Endocrine Society Student Research Award, 1994 Pathogenic Role of Stem Cell Factor in Infertile Men with Sertoli Cell Only Syndrome, Baylor College of Medicine-Karolinska Institute Research Fellowship Award, 1997 Compartmentalized Bone Regeneration of Cranial Defects with Biodegradable Barriers: an Animal Model, Baylor College of Medicine, Houston, Texas Basic Science High Honors, 1995 ' Butler Award for Academic Excellence, 1995 Alumni Award for Academic Excellence, 1996 Alpha Omega Alpha, 1997 - 1998 (elected Junior year) Graduation with Highest Honors, 1998 Most Outstanding Research by a Medical Student, 1998 Outstanding Student in Orthopaedic Surgery, 1998 Lange Medical Research Award, Baylor College of Medicine, 1998 , Class Valedictorian, 1998 : Michael E. DeBakey Scholar Award, 1998 University of California, Los Angeles Physician of the Year nominee, 2001 Emergency Department Consultant of the Year nominee, 2001 Hibbs Award Nominee, Basic Science, Scoliosis Research Society, 2005 . Three-point versus Two-point fixation for Thoracolumbar Burst Fractures. Hibbs Award Nominee, Basic Science, Scoliosis Research Scociety, 2005 Novel Transplantation of Preconditioned Schwann Cells Following Spinal Cord Contusion Injury. Scoliosis Research Society Edgar Dawson Traveling Fellowship, 2605 Outstanding Paper Nominee, Cervical Spine Research Society, 2005 Novel Transplantation of Preconditioned Schwann Cells Following Spinal Cord Contusion Injury. University of California, Irvine . Faculty Teaching Award, Orthopaedic Surgery, 2005 D ®@ American Orthopaedic Association Emerging Leaders, 2005-2009 Fo American Orthopaedic Association - Japanese Orthopaedic Association Exchange Traveling Fellow, 2008 Outstanding Paper Award Winner, Cervical Spine Research Society, 2008 — The Role of Durotomy and Duraplasty Following Cervical Spinal Cord Injury in an Animal Model, Best Paper Award Winner, American College of Spine Surgery, 2009 The Role of Durotomy and Duraplasty Following Cervical Spinal Cord Injury in an Animal Model, The Harold and Nancy Willingham Award for Outstanding Research Paper, Western Orthopaedic Association, 2009 Biomechanical Evaluation Of Short-Segment Posterior Instrumentation With Crosslinks In An Unstable Human Burst Fracture Model, i Hibbs Award Nominee, Basic Science, Scoliosis Research Society, 2009 Early Surgical Decompression with Duraplasty in Acute Spinal Cord Injury Improves Functional Recovery in an Animal Model, Resident Research Award, California Orthopaedic Association, 2010 Analysis of Prognostic Factors in Chordoma Using the California Cancer Registry. Triumvirate Grant Award, University of California, 2010 Quantitative MRI and MRA to Study Chronic Discogenic Low Back Pain, Orange County Medical Association, Physicians of Excellence, 2011-2013 Southern California “SuperDoctors”, Los Angeles Magazine, 2012-2013 RESEARCH GRANTS AND WORKS IN PROGRESS: Walter Lorenz Surgical Research Grant, 1998 - 1999 Compartmentalized Bone Regeneration of Cranial Defects with Biodegradable Barriers: an Animal Model Principal Investigator $43,000 total costs Stryker Biotech Spine Research Grant, 2005 - 2007 Spinal Cord Injury Research Grant Principal Investigator @ ® 34000 total costs EBI Spinal Cord Injury Research Grant, 2005 - 2007 Novel Transplantation of Preconditioned Schwann Cells Following Spinal Corq Contusion Injury Principal Investigator 340,000 total costs Spinewave Lumbar Sagittal Balance Research Grant, 2005 - 2008 Role of Intradiscal Expansion of Interbody Implants in Improving Lumbar Sagittal Balance Principal Investigator 872,450 total costs Roman Reed Spinal Cord Injury Research Fund of California, 2007 - present Carbohydrate Metabolism Impairments in Chronic Human Spinal Cord Injury Co-Investigator 326,850 total costs Dept. of Defense, U.S. Army Medical Research and Material Command, Congressionally Directed Medical Research Programs, Breast Cancer Research Program, 2007 - present Development and Evaluation of a Novel Radiation Therapy Technique for the Treatment of Vertebrae with Metastatic Lesions Co-Investigator 83499,434 total direct costs, $761,637 total costs (direct+indirect) University of California, Triumvirate Research Grant, 2010-2011 Quantitative MRI and MRA to Study Chronic Discogenic Low Back Pain Co-Principal Investigator . $15,000 total costs National Institutes of Health, R-21 Grant Application, 2010 MRI and MRA of Discogenic Low Back Pain Co-Investigator $275,000 total direct costs, $420,750 total costs (direct+ indirect) National Institutes of Health, R-01 Grant Application, 2010 Pathophysiology of Intervertebral Discs in Acute and Chronic Low Back Pain Co-Investigator 81,000,000 total direct costs, 31,460,490 total costs (direct+indirect) PEER REVIEWED PUBLICATIONS: 1. Transcriptional and Posttranscriptional Regulation of Inhibin alpha-Subunit Gene Expression in Rat Sertoli Cells by 8-Bromo-3", 5 "-Cyclic-Adenosine 10. 11. 12. Monophosphate. Najmabadi H, Rosenberg LA, Yuan QX, Bhatia N, Albiston AL, Burger H, Bhasin S; Molecular Endocrinology, 7(4): 469-476, 1993. Congenital Syndromes Associated with Nonmelanoma Skin Cancer. Gherardini G, Bhatia N, Stal S; Clinics of Plastic Surgery, 24(4):649-661, 1997. Barriers: an Animal Model. Stal S, Tjelmeland K, Hicks J, Bhatia N, Eppley B, Hollier L; Journal of Craniofacial Surgery, 12(1):51-47, 2001. Current Information Regarding the Biochemical and Genetic Events Which Occur , During Disc Degeneration. Bhatia N, Wang J; Current Opinion in Orthopaedics, 14(3):153-158, 2003. Adjacent Segment Degeneration in the Lumbar Spine. Ghiselli G, Wang JC, Bhatia NN, Hsu WK, Dawson EG; J Bone Joint Surg Am, 86-A(7):1497-1503, 2004. The Role of the Sternocleidomastoid Muscle Flap for Esophageal Fistula Repair in Anterior Cervical Spine Surgery. Navarro R, Javahery R, Eismont F, Amold DJ, Bhatia NN, Vanni S, Levi AD; Spine, 30(20):617-633, 2005. Body Mass Index in Patients with Slipped Capital Femoral Epiphysis: A Predictive Model. Bhatia NN, Pirpiris M, Otsuka N; Journal of Pediatric Orthopaedics, 26(2):197-9, 2006. Transplantation of Preconditioned Schwann Cells in Peripheral Nerve Grafts , after Contusion in the Adult Spinal Cord: Improvement of Recovery in a Rat Model. Rasouli A, Bhatia NN, Suryadevara S, Cahill K, Gupta R; J Bone Joint Surg Am, 88(11):2400-10, 2006. Minimally Invasive Atlanto-Odontoid Joint Injection for Involvement in Rheumatoid Arthritis Kostanian VJ, Mathews MS, Westhout FD, Bhatia NN; Interventional Radiology, 12(4):359-363, 2006. Wound Complications from Idiopathic Clubfoot Surgery: a Comparison of the Modified Turco and the Cincinnati Treatment Methods. Hsu WK, Bhatia NN Raskin A, Otsuka NY; Journal of Pediatric Orthopaedics, 27(3):329-332, 2007. Transplantation of Preconditioned Schwann cells following Hemisection Spinal Cord Injury. Dinh P, Bhatia NN, Cahill K, Gupta R; Spine, 32(9):943-9, 2007. A Prospective Evaluation of Diagnostic Modalities in Pediatric Back Pain. , Bhatia NN, Chow G, Timon S, Watts HG; Journal of Pediatric Orthopaedics. 28(2):230-3, 2008. 13. 14, 15. 16. 17. 18. 19. 20. 21. 22, 23, 24, @ @ Orthopaedic Surgeons and Spinal Cord Injury Patients. Bhatia NN Gupta G; AAOS Now, 3(2):2009, 27-31. Resection of Glial Scar Following Spinal Cord Injury. Rasouli A, Bhatia N, Dinh P, Cahill K, Suryadevara S, Gupta R; J Orthop Research, 27(7):931-6, 2009. oo Biomechanical Evaluation of Short-Segment Posterior Instrumentation With ang Without Crosslinks in a Human Cadaveric Unstable Thoracolumbar Burst Fracture Model. Wahba G, Bhatia N, Bui C, Lee K, Lee TQ; Spine, 35(3):278- 85, 2010. Advances in the Management of. Spinal Cord Injury. Gupta R, Bathen M, Smith J, Levi AD, Bhatia NN, Steward O; J Am Acad Ortho Surg, 18(4):210-22, 2010. The Role of Early Surgical Decompression of the Intra-Dural Space Following Cervical Spinal Cord Injury in an Animal Model. Smith J » Anderson R, Pham T, Bhatia N, Steward O, Gupta R; J] Bone Joint Surg Am, 92(5):1206-14, 2010. Modic Type I changes of the Lumbar Spine in Golfers. Mefford J, Sairyo K, Sakai T, Hopkins J, Inoue M, Amari R, Bhatia N, Dezawa A, Yasui N; Skeletal Radiology, 40(4):467-73, 2011. Biomechanical Evaluation of an Expandable Cage in Single Segment Posterior Lumbar Interbody Fusion. Bhatia NN, Lee KH, Bui CN, Luna M, Wahba GM, Lee TQ; Spine, 37(2):79-85, 2012, MRI Changes of the Spinal Subdural Space after Lumbar Spine Surgeries: Report of Two Cases. Sakai T, Sairyo K, Bhatia NN Miyagi R, Tamura T, Katoh S, Yasui N; Asian Spine J, 5(4):262-6, 2011. Retrospective Study of Deep Surgical Site Infections Following Spinal Surgery and the Effectiveness of Continuous Irrigation. Chikawa T, Saka T, Bhatia NN, Sairyo K, Utsunomiya R, Nakamura M, Nakano S, Shimakawa T, Minato A; Br J Neurosurg, 25(5):621-4, 2011. Posterior Cervical Laminoplasty in the North American Population: A Minimum of Two Year Follow-Up. Submitted for publication, Anterior Thoracolumbar Reconstruction Surgery for Late Collapse Following Vertebroplasty: Report of Three Cases. Miyagi R, Sakai T, Bhatia NN, Sairyo K, Katoh S, Chikawa T; J Med Inves 58(1-2):148-53, 2011. Flavokawain B, a Kava Chalcone, Induces Apoptosis in Synovial Sarcoma Cell Lines. Sakai T, Ramez E, Guo Y, Kim KJ, Mefford J, Hopkins J, Bhatia NN, Zi X, Hoang BH; J of Orthop Res, 30(7):1045-50, 2012. ® ® | ’ 25. Drivers of Surgery for the Degenerative Hip, Knee, and Spine: A Systematic Review. Bederman SS, Rosen CD, Bhatia NN, Kiester PD, Gupta R; Clin Orthop Relat Res, 2012 Apr;470(4):1090-105. 26. Analysis of Prognostic Factors in Patients With Chordoma Using the California Cancer Registry. Lee J, Bhatia NN, Hoang B, Ziogas A, Zell J; I B one Joint Surg—--- - Am, 94(4):356-63, 2012. 27. Endoscopic Excision of a Juxtafacet Cyst in an Adolescent Athlete: A Case Report. Hopkins J, Mefford J, Sakai T, Bhatia N Sairyo K; J Neurol Surg A Cent Eur Neurosurg. 2013 Dec;74 Suppl 1:¢66-9. . 28. Clinical Outcomes of Spinal Surgery in Patients Treated with Hemodialysis. Chikawa T, Sakai T, Bhatia NN, Miyagi R, Sairyo K, Goda Y, Nakamura M, Nakano S, Shimakawa T, Minato A; J Spinal Dis Tech, 2013 Aug;26(6):321-4. 29. Diffusion-Weighted Imaging and Diffusion Tensor Imaging of Asymptomatic Lumbar Disc Herniation. Sakai, T, Miyagi, R, Yamabe, E, Fujinaga Y; Bhatia NN; Yoshioka, H; J Med Invest. 2014;61(1-2):197-203. . 30. Fixation Techniques for Complex Traumatic Sacral Fractures: A Sytematic Review. Bederman SS, Hassan JM, Shah KN, Kiester PD, Bhatia NN, Zamorano DP; Spine, 2013 Jul 15;38(16):E1028-40. 31. Robotic Guidance for S2-Alar-Nliac Screws in Spinal Deformity Correction. Bederman SS, Hahn P, Colin V, Kiester DP, Bhatia NN, J Spinal Dis Tech, 2013 Jul 26. [Epub ahead of print] 32, Useof Lateral Access in the Treatment of the Revision Spine Patient. Bederman SS, Le VH, Pahlavan S, Kiester DP, Bhatia NN, Deviren V; Scientific World J, 2012;2012:308209 33. Surgical Techniques for Spinopelvic Reconstruction Following Total Sacrectomy: A Systematic Review. Bederman SS, Shah KN, Hassan JM, Hoang BH, Kiester PD, Bhatia NN; Eur Spine J, 2014 Feb;23(2):305-19. 34. Biomechanical Comparison of Two Transsacral Screws versus Triangular Osteosynthesis Fixation for Vertically Unstable Transforaminal Sacral Fractures. Accepted for publication. Orthopaedics, 2014. 35. The Influence of Insurance Status on the Surgical Treatment of Acute Spinal Fractures. Submitted for publication. BOOK CHAPTERS: 10. 11. 12. 13. ® Q Costal Cartilage Grafts. In Evans G. ed, Operative Plastic Surgery. Appleton and Lange, Stamford, CT, 2000. The Management of Spinal Cord Injury in Thoracolumbar Trauma, In Reitman... Cred.; Management of Thoracolumbar Fr: es, American Academy of ‘ Orthopaedic Surgery, Rosemont, IL, 2004. Disorder, Disease, and Injuries of the Spine. In Skinner H. ed. Current Diagnosis and Treatment in Orthopaedics. Lange/Mc-Graw Hill, New York, NY, 2006. Spinal Cord and Peripheral Nerve Injury. In Orthopaedic Knowledge Update 9. American Academy of Orthopaedic Surgery, Rosemont, IL, 2007. Imaging of the Spine. In Lieberman, JR. ed. In Orthopaedic Board Review. American Academy of Orthopaedic Surgery, Rosemont, IL, 2008. Thoracic Spinal Stability: Decision Making. In Patel V., ed, Spine Trauma ~ Surgical Techniques. Springer, Heidelberg, Germany, 2010. Lumbar Spinal Stability: Decision Making. InPatel V., ed. Spine Trauma - Surgical Techniques. Springer, Heidelberg, Germany, 2010. Post-operative Spinal Infections. In Garfin S., ed. Rothman-Simeone: The Spine, 6th Edition. Elsevier, Philadelphia, PA, 2011. Pre-Sacral Lumbar Fusion with TranS1 Axial IF. In Wang J., ed. Advanced Reconstruction: The Spine. American Academy of Orthopaedic Surgery, Rosemont, IL, 2011. Long-term Outcomes and Complications following Anterior and Posterior Cervical Spine Surgery. In Rao R., ed. Seminars in Spine Surgery. Stellar Medical Publications, Plymouth, MA, 2009. Spondylolisthesis and Spondylolysis. In Orthopaedic Knowledge Update 10. American Academy of Orthopaedic Surgery, Rosemont, IL, 2011. Central Cord Syndrome: Acute Decompression versus Watch and Wait. In The Cervical Spine, S* Edition. Lippincott Williams and Wilkins, Philadelphia, PA. In press. Spine Trauma: Low Lumbar Spine (including L3-L5). In Spine Surgery Basics. Springer, Heidelberg, Germany. In Press. 14. Thoracolumbar Fractures. In Garg B., ed., Mastering Techniques in opaedi Surgery: Spine. Jaypee Publishers, New Delhi, India, 2012. PUBLISHED ABSTRACTS: 1. Pathogenic Role of Stem Cell Factor in Infertile Men with Sertoli Cell Only Syndrome. Transactions of the Endocrine Society, 1994. Z Adjacent Segment Degeneration After Lumbar Fusion: Long Term Survivorship Analysis of 217 Patients. Proceedings of the North American Spine Society, 2001. 3. Proximal Segment Degeneration Following Posterior Lumbosacral Fusions (L4- SI and L5-S1). Transactions of the Scoliosis Research Society, 2002. 4, A Prospective Evaluation of Diagnostic Modalities in Pediatric Back Pain. Transactions of the Scoliosis Research Society, 2002. 5% A Prospective Evaluation of Diagnostic Modalities in Pediatric Back Pain. Transactions of the American Academy of Orthopaedic Surgery, 2003. 6. Prospective Randomized Study of Modified Harrington Instrumentation Versus Segmental Instrumentation in Adolescent Idiopathic Scoliosis. Proceedings of the North American Spine Society, 2003. y Adjacent Segment Degeneration After Posterior Lumbosacral Fusion. Proceedings of the North American Spine Society, 2003. 8. Diagnostic Techniques Used in Pediatric Back Pain. Proceedings of the North American Spine Society, annual meeting, 2003. 9. Can Bilateral Hip Involvement with Slipped Capital Femoral Epiphysis be Predicted by the Body Mass Index? Transactions of the Pediatric Orthopaedic Society of North America, 2004. 10. Body Mass Index in Patients with Slipped Capital Femoral Epiphysis. Transactions of the American Academy of Orthopaedic Surgery, 2004. 11. Outcome Differences for Primary and Recurrent Disc Excision Patients Treated by a Single Surgeon. Proceedings of the North American Spine Society, 2004. 12. 13. ® @ Novel Transplantation of Preconditioned Schwann Cells Following Spinal Cord Contusion Injury. International Meeting for Advanced Spinal Techniques (IMAST), annual meeting, 2005, Resection of Glial Scar Following Spinal Cord Injury. Transactions of the International Meeting for Advanced Spinal Techniques (IMAST), 2005. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24, Novel Transplantation of Preconditioned Schwann cells for Spinal Cord Injury with a Contusion Model. The Spine Journal 4(4S): 33S, July/August 2005. Results of Cervical Open-Door Laminoplasty in Patients with Tandem Cervical and Lumbar Stenosis. The Spine Journal 4(4S): 2005. Results of Open Door Laminoplasty for Cervical Spondylotic Myelopathy in a North American Population. The Spine Journal 4(4S): 2005. Three-point versus Two-point fixation for Thoracolumbar Burst Fractures. Transactions of the Scoliosis Research Society, 2005. Russell Hibbs Award Finalist. Novel Transplantation of Preconditioned Schwann Cells Following Spinal Cord Contusion Injury. Transactions of the Scoliosis Research Society, 2005. Russell Hibbs Award Finalist. Results of Open Door Laminoplasty for Cervical Spondylotic Myelopathy in the Elderly Population. Proceedings of the Cervical Spine Research Society, 2005. Novel Transplantation of Preconditioned Schwann Cells Following Spinal Cord Contusion Injury. Proceedings of the Cervical Spine Research Society, 2005. Results of Open Door Laminoplasty for Cervical Spondylotic Myelopathy in a North American Population. Proceedings of the Cervical Spine Research Society, 2005. Transplantation of Preconditioned Schwann cells following Hemisection Spinal Cord Injury. Transactions of the Orthopaedic Research Society 31:1257, 2006. Transplantation of Preconditioned Schwann cells for Spinal Cord Injury with a Contusion Model. Transactions of the Orthopaedic Research Society 31:1261, 2006. Resection of Glial Scar Following Spinal Cord Injury. Transactions of the Orthopaedic Research Society 31:1258, 2006. 10 25. 26. 27. 28. 29. 30. 31 32. 33. 34, o @ Do Patients with Concurrent Lumbar Stenosis Have Impaired Results Following Cervical Laminoplasty for Spondylotic Myelopathy? Bhatia N, Geck M, Gottliep J, Harrison R, Eismont F; Proceedings of the North America Spine Society and Japanese Spine Research Society, Spine Across the Sea: 51 -52, 2006. Laminoplasty for Cervical Spondylotic Myelopathy in the Elderly North American * Population: Minimum of Two Year Follow-Up. Bhatia N, Geck M, Gottlieb J, Harrison R, Eismont F; Proceedings of the North America Spine Society and Japanese Spine Research Society, Spine Across 2 ——— Novel kyphoplasty/brachytherapy technique for the treatment of vertebral metastases: A mathematical modeling feasibility study. Proceedings of the Chao Family Comprehensive Cancer Center Conference, Rancho Mirage, CA, 2006. Novel Iyphoplasty/brachytherapy technique for the treatment of vertebral metastases: A Monte Carlo feasibility study. Marcus P, Sehgal V, Al-Ghazi M, Ramsinghani N, Hoang B, Bhatia N, Skinner H, Keyak J; Med Physics 34:2475- 2475, 2007. The Role of Durotomy and Duraplasty Following Cervical Spinal Cord Injury in an Animal Model. Proceedings of the Cervical Spine Research Society 36th annual meeting, Austin, TX, 2008. Biomechanical Evaluation of Short-Segment Posterior Instrumentation with Crosslinks in an Unstable Human Burst Fracture Model. Transactions of the Orthopaedic Research Society annual meeting, Las Vegas, NV, 2009. Biomechanical Evaluation of an Expandable Cage in Single Segment Posterior Lumbar Interbody Fusion. Transactions of the Orthopaedic Research Society annual meeting, Las Vegas, NV, 2009, Biomechanical Comparison of Trans-Sacral and Triangular Osteosynthesis in a Vertically Unstable Pelvic Fracture Model. Transactions of the Orthopaedic Research Society annual meeting, Las Vegas, NV, 2009. The Role of Decompression with either Durotomy or Duraplasty Following Cervical Spinal Cord Injury. Transactions of the Orthopaedic Research Society annual meeting, Las Vegas, NV, 2009, Posterior Cervical Instrumentation: Past, Present, and Future and the Roy- Camille Technique of Lateral Mass Fixation. Bhatia N, Sairyo K. Transactions of the Japanese Society for Spine Surgery and Related Research, 38" Annual Meeting, Kobe, Japan, 2009. 38. 36. 37. 38. 39. 40. 41, 42. Spinal Surgery and Implants. Bhatia N. Proceedings of the American Society of Mechanical Engineering 4® Frontiers in Biomedical Devices Conference and Exhibition, Irvine, CA, 2009. : Biomechanical Evaluation of an Expandable Cage in Single Segment Posterior Lumbar Interbody Fusion. Bhatia N, Lee K, Bui C, Whaba G, Estess A, Luna M, Lee TQ. Proceedings of the American Society of Mechanical Engineering 4h Frontiers in Biomedical Devices Conference and Exhibition, Irvine, CA, 2009, Biomechanical Evaluation of Short-Segement Posterior Instrumentation With Crosslinks in an Unstable Human Burst Fracture Model. ‘Wahba G, Bhatia N, Lee T. Proceedings of the American Society of Mechanical Engineering 4 Frontiers in Biomedical Devices Conference, American Society of Mechanical Engineering, Irvine, CA, 2009. Biomechanical Comparison of Trans-Sacral and Triangular Osteosynthesis in a Vertically Unstable Pelvic Fracture Model, Zamorano D, Min K, Wahba G, Bhatia N, Garcia I, Lee T. Proceedings of the American Society of Mechanical Engineering 4™ Frontiers in Biomedical Devices Conference, American Society of Mechanical Engineering, Irvine, CA, 2009. Early Surgical Decompression with Duraplasty in Acute Spinal Cord Injury Improves Functional Recovery in an Animal Model. Smith J » Anderson R, Pham T, Bhatia N, Steward O, Gupta R. Transactions of the Scoliosis Research Society annual meeting, San Antonio, 2009. Short-Segment Posterior Instrumentation in Unstable Thoracolumbar Burst Fractures: Do Crosslinks Improve Biomechanical Stability? Wahba G, Bhatia N, Bui C, Lee K, Lee TQ. Proceedings of the annual meeting of the North American Spine Society, San Francisco, 2009. The Role of Decompression with Either Durotomy or Duraplasty Following Cervical Spinal Cord Injury. Smith J, Anderson R, Pham T, Bhatia N, Steward O, Gupta R. Proceedings of the annual meeting of the North American Spine Society, San Francisco, 2009. Comparison of Trans-sacral and Triangular Osteosynthesis in an Unstable Pelvic , Fracture. Min KS, Zamorano D, Wahba G, Garcia I, Bhatia N, Lee TQ. Transactions of the annual meeting of the American Academy of Orthopaedic Surgery, New Orleans, 2010. 12 43. 44, 45. 46. 47. 48. 49. Analysis of Prognostic Factors in Chordoma Using the California Cancer Registry. Lee J, Bhatia N, Hoang B, Ziogas A, Zell J. Proceedings of the annua] meeting of the California Orthopaedic Association, Lake Tahoe, 2010. Analysis of Prognostic Factors in Chordoma Using the California Cancer Registry. Lee J, Bhatia N, Hoang B, Ziogas A, Zell J. Transactions of the annual meeting of the American Academy of Orthopaedic Surgery, San Diego, CA, 2011. ’ Biomechanical Comparison of Unilateral versus Bilateral C1-C2 Fixation Following Odontoid Fracture. Bhatia N, Rama A, Sievers B, Quigley R, Lee TQ, Proceedings of the annual meeting of the American College of Spine Surgery, Las Vegas, NV, 2011. The Influence. of Insurance Status on the Surgical Treatment of Acute Spine Fractures. Proceedings of the annual meeting of the Cervical Spine Research Society, Phoenix, AZ, 2012. Biomechanical Study Of Sublaminar Polyester Bands Versus Pedicle Screws In Adolescent Idiopathic Scoliosis Model. Transactions of the annual meeting of the American Academy of Orthopaedic Surgery, Chicago, IL, 2013. ’ The Influence of Insurance Status on the Surgical Treatment of Acute Spinal Fractures. Proceedings of the annual meeting of the American Orthopaedic Association, Denver, CO, 2013. Exploring the Efficacy of a Self-Sterilizing Orthobiologic PEEK asa Viable Biomateral for Spinal Surgery. The Spine J, 2013, 13:9, S162-163. SCIENTIFIC PRESENTATIONS: Pathogenic Role of Stem Cell Factor in Infertile Men with Sertoli Cell Only Syndrome. The Endocrine Society, annual meeting, 1994. Adjacent Segment Degeneration After Lumbar Fusion: Long Term Survivorship Analysis , of 217 Patients. North American Spine Society, annual meeting, 2001. Proximal Segment Degeneration Following Posterior Lumbosacral Fusions (L4-S1 and L5-S1). Scoliosis Research Society, annual meeting, 2002, A Prospective Evaluation of Diagnostic Modalities in Pediatric Back Pain. Scoliosis Research Society, annual meeting, 2002. 13 © ® Diagnostic Techniques Used in Pediatric Back Pain. North American Spine Society, annual meeting, 2003. Adjacent Segment Degeneration After Posterior Lumbosacral Fusion. North American Spine Society, annual meeting, 2003. Prospective Randomized Study of Modified Harrington Instrumentation Versus Segmental Instrumentation in Adolescent Idiopathic Scoliosis. North American Spine Society, annual meeting, 2003 me + A Prospective Evaluation of Diagnostic Modalities in Pediatric Back Pain. American Academy of Orthopaedic Surgery, annual meeting, 2003. Outcome Differences for Primary and Recurrent Disc Excision Patients Treated bya Single Surgeon. North American Spine Society, annual meeting, 2004. Body Mass Index in Patients with Slipped Capital Femoral Epiphysis. American Academy of Orthopaedic Surgery, annual meeting, 2004. Can Bilateral Hip Involvement with Slipped Capital Femoral Epiphysis be Predicted by the Body Mass Index? Pediatric Orthopaedic Society of North America, annual meeting, 2004, , Novel Transplantation of Preconditioned Schwann Cells Following Spinal Cord Contusion Injury. Intemational Meeting for Advanced Spinal Techniques (IMAST), annual meeting, 2005. Resection of Glial Scar Following Spinal Cord Injury. International Meeting for Advanced Spinal Techniques (IMAST), annual meeting, 2005. Results of Cervical Open-Door Laminoplasty in Patients with Tandem Cervical and Lumbar Stenosis. North American Spine Society, annual meeting, 2005. Results of Open Door Laminaplasty for Cervical Spondylotic Myelopathy in a North American Population. North American Spine Society, annual meeting, 2008, Novel Transplantation of Preconditioned Schwann Cells Following Spinal Cord Contusion Injury. North American Spine Society, annual meeting, 2008S. ' Three-point versus Two-point fixation for Thoracolumbar Burst Fractures, Scoliosis Research Society, annual meeting, 2005. Hibbs Award Nominee. 14° @ @ Novel Transplantation of Preconditioned Schwann Cells Following Spinal Cord Contusion Injury. Scoliosis Research Society, annual meeting, 2005. Hibbs Award Nominee, Results of Open Door Laminoplasty for Cervical Spondylotic Myelopathy in a North American Population. Cervical Spine Research Society, annual meeting, 2005. Novel Transplantation of Preconditioned Schwann Cells Following Spinal Cord Contusion Injury. Cervical Spine Research Society, annual meeting; 2005———-— — Outstanding Paper nominee. Results of Open Door Laminoplasty for Cervical Spondylotic Myelopathy in the Elderly Population. Cervical Spine Research Society, annual meeting, 2005. Novel Transplantation of Preconditioned Schwann cells for Spinal Cord Injury with a ' Contusion Model. Orthopaedic Research Society annual meeting, 2006. Resection of glial scar following spinal cord injury. Orthopaedic Research Society annual meeting, 2006. Transplantation of Preconditioned Schwann cells following Hemisection Spinal Cord Injury. Orthopaedic Research Society annual meeting, 2006. Do Patients with Concurrent Lumbar Stenosis Have Impaired Results Following Cervical Laminoplasty for Spondylotic Myelopathy? North America Spine Society and Japanese Spine Research Society, Spine Across the Sea, 2006. Laminaplasty for Cervical Spondylotic Myelopathy in the Elderly North American Population: Minimum of Two Year Follow-Up. North America Spine Society and Japanese Spine Research Society, Spine Across the Sea, 2006. Novel kyphoplasty/brachytherapy technique for the treatment of vertebral metastases: A mathematical modeling feasibility study. Chao Family Comprehensive Cancer Center Conference, Rancho Mirage, CA, Nov 3-5, 2006. Lost in Translation? Is Cervical Laminoplasty Valid in the North American Population. Japanese Orthopaedic Assocation annual meeting, Sapporo, Japan, 2008. Cervical Open-Door Lamnioplasty in North American Spondylotic Myelopathic Patients. 5th Alps Orthopaedic Seminar in Shinshu University, Shinshu, Japan, 2008. The Role of Durotomy and Duraplasty Following Cervical Spinal Cord Injury in an Animal Model. Cervical Spine Research Society, 36™ annual meeting, Austin, TX, 2008. 15 ® D Biomechanical Evaluation of Short-Segment Posterior Instrumentation with Crosslinks in an Unstable Human Burst Fracture Model. Orthopaedic Research Society annual meeting, Las Vegas, NV, 2009, ; Biomechanical Evaluation of an Expandable Cage in Single Segment Posterior Lumbay Interbody Fusion. Orthopaedic Research Society annual meeting, Las Vegas, NV, 2009. Biomechanical Comparison ; Vertically Unstable Pelvic Fracture Model. Orthopaedic Research Society annual meeting, Las Vegas, NV, 2009. 3 The Role of Decompression with either Durotomy or Duraplasty Following Cervical Spinal Cord Injury. Orthopaedic Research Society annual meeting, Las Vegas, NV, 2009. Posterior Cervical Instrumentation: Past, Present, and Future. Japanese Society for Spine Surgery and Related Research, 38" Annual Meeting, Kobe, Japan, 2009. Biomechanical Evaluation of Short-Segment Posterior Instrumentation with Crosslinks in an Unstable Human Burst Fracture Model. Frontiers in Biomedical Devices ¥ Conference, American Society of Mechanical Engineering, Irvine, CA, 2009, Biomechanical Evaluation of an Expandable Cage in Single Segment Posterior Lumbar Interbody Fusion. Frontiers in Biomedical Devices Conference, American Society of Mechanical Engineering, Irvine, CA, 2009. Biomechanical Comparison of Trans-Sacral and Triangular Osteosynthesis in a Vertically Unstable Pelvic Fracture Model. Frontiers in Biomedical Devices Conference, American Society of Mechanical Engineering, Irvine, CA, 2009. Spinal Surgery and Implants. Frontiers in Biomedical Devices Conference, American Society of Mechanical Engineering, Irvine, CA, 2009. Early Surgical Decompression with Duraplasty in Acute Spinal Cord Injury Improves Functional Recovery in an Animal Model. Scoliosis Research Society, 44% Annual Meeting, San Antonio, TX, 2009. Short-Segment Posterior Instrumentation in Unstable Thoracolumbar Burst Fractures: Do Crosslinks Improve Biomechanical Stability? North American Spine Society, 24" Annual Meeting, San Francisco, 2009. 16 ® ® The Role of Decompression with Either Durotomy or Duraplasty Following Cervical Spinal Cord Injury. North American Spine Society, 24™ Annual Meeting, San Francisco, 2009. Comparison of Trans-sacral and Triangular Osteosynthesis.in an Unstable Pelvic Fracture. American Academy of Orthopaedic Surgery, Annual Meeting, New Orleans, 2010. ‘ Analysis of Prognostic Factors in Chordoma Using the California Cancer Registry.— ~~" California Orthopaedic Association, Annual Meeting, Lake Tahoe, CA, 2010. Prognostic Factors for Patients with Chordoma Western Orthopaedic Association, Annual Meeting, Monterey, CA, 2010. Analysis of Prognostic Factors in Chordoma Using the California Cancer Registry. North American Spine Society, Annual Meeting, Orlando, FL, 2010. Flavokawain B, a Kava Chalcone, Induces Apoptosis in Synovial Sarcoma Cell Lines. i American Association for Cancer Research, Annual Meeting, Orlando, FL, 2011. Analysis of Prognostic Factors in Chordoma Using the California Cancer Registry. American Academy of Orthopaedic Surgery, Annual Meeting, San Diego, CA, 2011. Biomechanical Comparison of Unilateral versus Bilateral C1-C2 Fixation Following Odontoid Fracture. American College of Spine Surgery, Annual Meeting, Las Vegas, NV, 2011. Biomechanical Evaluation of Single Rod Versus Dual Rod Posterior Spinal Fixation for Adolescent Idiopathic Scoliosis in a Sawbone Model, Orthopaedic Research and Education Foundation Research Symposium, Irvine, CA, 2012. The Influence of Insurance Status on the Surgical Treatment of Acute Spine Fractures. Cervical Spine Research Society, Annual Meeting, Phoenix, AZ, 2012. . Biomechanical Study Of Sublaminar Polyester Bands Versus Pedicle Screws In Adolescent Idiopathic Scoliosis Model. American Academy of Orthopaedic Surgery, Annual Meeting, Chicago, IL, 2013. The Influence of Insurance Status on the Surgical Treatment of Acute Spinal Fractures. American Orthopaedic Association, Annual Meeting, Denver, CO, 2013. 17 D ® Antimicrobial Efficacy of a Novel Orthobiologic PEEK in Treating Surgical Site Spine Infections. North American Spine Society, Summer Session, Boca Raton, FL, 2013. * 4 Exploring the Efficacy of a Self-Sterilizing Orthobiologic PEEK as a Viable Biomateriq] Jor Spinal Surgery. North American Spine Society, Annual Meeting, New Orleans, LA, 2013. INVITED LECTURES: Kartagener's Syndrome in a Patient with Craniofacial Abnormalities. Plastic Surgery Grand Rounds, Baylor College of Medicine, 1996 Posterior Cervical Surgery. Symposium for Minimally Invasive and Posterior Cervical Surgery, 2004 New Technologies in Spine Surgery. Neurosurgery Grand Rounds, University of California, Irvine, 2005 Low Back Pain and the Primary Care Physician. Family Practice Review Symposium, Long Beach Memorial Hospital, 2005 Lumbar Spinal Stenosis and Back Pain. Grand Rounds, Kaiser Whittier Medical Center, 2005 Spinal Cord Injury Complications. Grand Rounds, Torrance Memorial Medical Center, 2005 Posterior Cervical Laminoplasty. Blackstone Instructional Meeting, 2005 Spinal Cord Injury. Seaspine Users Meeting, 2005 Adult Back Pain. Grand Rounds, Lakewood Regional Medical Center, 2005 Diagnostic Techniques Used in Pediatric Back Pain. University of California, Irvine, Graduate Research Forum, 2005 New Technologies in Spinal Surgery. Neurosurgery Grand Rounds, University of California, Irvine, 2005 ' Spinal Cord Injury Complications, Grand Rounds, Torrance Memorial Hospital, Torrance, CA, 2005 18 rechmign Posterior Cervical Fixation, Current Concepts and Techniques for Spine Surgery Symposium, San Diego, CA 2005 Modern Techniques in Spinal Surgery. Westem Orthopaedic Association, 2005 Laminoplasty in the North American Population, University of California, Irvine, ——--- _G G 5 Posterior Cervical Surgery and Instrumentation, AO North America, Chicago, IL 2006, Low Back Pain. Grand Rounds, South Coast Medical Center, 2006 Lumbar Spinal Disorders and the Primary Care Physician. Family Practice Review Symposium, UC Irvine-Long Beach Memorial Hospital, Long Beach, CA 2006 Cervical Evaluation in the Multi-Trauma Patient, University of California, Irvine, Graduate Research Forum, 2007 Anterior Cervical Surgery Advanced Technique, Cervical and Lumbar Instructional Course, Santa Monicz. C4, 2007 Lumbar Spinal Stenosis, Back Pain, and Disc Herniations, Family Practice Review Symposium, UC Irvine-Long Beach Memorial Hospital, Long Beach, CA 2007 Complications of Posterior Cervical Surgery. Complex Cervical Surgery Symposium, Denver, CO, 2008 Modern Techniques in Spinal Surgery. University of California, Irvine, Department of Biomechanical Engineering, BME 200, 2008 Outcomes of Posterior Cervical Laminaplasty in Various American Population. Grand Rounds, Kyoto Prefectural University of Medicine, Kyoto, Japan, 2008 ’ The Efficacy of Posterior Cervical Laminoplasty in Elderly Myelopathic Patients, Grand Rounds, Dokkyo Medical University, Dokkyo, J: apan, 2008 Lost in Translation? Is Cervical Laminoplasty a Valid Technique in the North American Population? Grand Rounds, Department of Orthopaedic Surgery, Wakayama Medical University, Wakayama, Japan, 2008 19 Modern Updates in American Ortho pedics and Spine Surgery. Grand Rounds, Tokushima University, Tokushima, Japan, 2009 — Spinal Surgery and-Impiants; The American Society of Mechanical Engineering 4% Co Frontiers in Biomedical Devices Conference and Exhibition, Irvine, CA, 2009 Biomechanical Evaluation of an Expandable Cage in Single Segment Posterior Lumbar Interbody Fusion. The American Society of Mechanical Engineering 4* Frontiers in Biomedical Devices Conference and Exhibition, Irvine, CA, 2009 agement. Contemporary Concepts in Spine Surgery, American College of Spi nal Surgery, Newport Beach, CA, 2009 Cervical Laminoplasty versys Laminectomy and Fusion. Advanced Techniques in Spine Surgery, Boston, MA, 2009, Techniques for Open and Minimally Invasive Transforaminal Lumbqy Interbody Fusion ] (TLIF). Advanced Techniques in Spine Surgery, Boston, MA, 2009, Minimally Invasive Cervica I Spine Surgery, Pain Management Grand Rounds, University of California, Irvine, 2010, Posterior Minimally Ivasive Approaches to the Cervical Spine. Instructional Course Lecture, American Academy of Orthopaedic Surgery, Annual Meeting, New ' Spinal Surgery Implants: Development and Modern Approach. 5" Annual Conference of Spine Surgeons of Spain and Portugal, Lisbon, Portugal, 2010, 20 cademy of Orthopaedic Surgery, Annuya} Meeti Diego, CA, 2011, Diagnosis and Management Primary Care Physicians Conference, 0 Emergent Cricothyroidotomy and Research Society Instruct] Minimally Invasive Posey Techniques in C Surgery, Annual Posterior Cervical Instrum 2012, Adult Spinal Deformity. MOC Re al Spine ng, San of Cervical Spinal Disorders, Annual Surgery for range, CA, 2011. Airway Management, 16% App ual Cervical Spine onal Course, Phoenix, AX, 2011 ior Cervical Spinal Surgery, Symposium in Advanced ervical Spine Surgery, American Academy of Orthopaedic Meeting, San Francisco, CA, 2012. entation and Fixation, The Art of Spine, Dana Point, CA, view Cours e, American Academy of Orthopaedic Surgery, San Francisco, CA 2012. Infections of the Spine. MOC Revi ew Course, Am erican Academy of Orthopaedic Surgery, San Francisco, CA 2012, 2} Tracheotomy and Crichothyroidotomy. Instructional Course Lecture, Cervical Spine Research Society, Annual Meeting, Los Angeles, CA, 2013. INVITED FACULTY: Symposium for Minimally Invasive and Posterior Cervical Surgery, San Diego, CA, 2004 Moderator, Basic Science, North American Spine Society 2005... Advanced Surgical Techniques Meeting, Santa Monica, CA, 2005 Family Practice Review Symposium, UC Irvine-Long Beach Memorial Hospital, Long Beach, CA 2005 Symposium for Lumbar and Cervical Surgery, New York, NY, 2005 Family Practice Review Symposium, UC Irvine-Long Beach Memorial Hospital, Long Beach, CA 2005 i Advanced Spinal Techniques, Dallas, Texas, 2006 19th Annual Disorders of the Spine, Whisilcr, Canada, 2007 Cervical and Lumbar Instructional Course, Santa Monica, CA 2007 20th Annual Disorders of the Spine, Whistler, Canada, 2008 Complex Cervical Surgery Symposia, Denver, Colorado, 2008 Visiting Professor, Wakayama Medical University, Japan, 2008 Visiting Professor, Dokkyo Medical University, Japan, 2008 Visiting Professor, Keio University, Japan, 2008 Invited Guest Lecturer, Japanese Orthopaedic Association Annual Meeting, Sapporo, Japan, 2008 Visiting Professor, Shinshu University School of Medicine, Japan, 2008 Visiting Professor, Kyoto Prefectural University of Medicine, Japan, 2008 Visiting Professor, Tokushima Prefectural University, Japan, 2009 22 Q ® Moderator, Posterior Cervical Surgery, Japanese Society for Spine Surgery and Related Research, 38" Annyaj Mecting, Kobe, Japan, 2009 Moderator, Post-operative Complications, Contemporary American College of Spinal Surgery, Moderator, Spinal Surgery and Implants, Frontiers in Biomedical Devices Conference, erican Society of Mechanica] Engineering, Irvine, CA, 2009 : Concepts in Spine Surgery, The Newport Beach, CA, 2009 Lecturer, Instructiona] Course Lectures, Advanced Techniques in Cervical American Academy of Orthopa, 2010. Spine Surgery, edic Surgery, Annual Meeting, New Orleans, LA, Lecturer, 5% Annual Conference of Spine Surgeons of Spain and Portugal, Lisbon, Portugal, 2010, Program Chair and Moderator, Annug Meeting, Western Orthopaedic Association, Monterey, CA, 2010. Moderator, Spinal Surgery and Implants, Frontiers in Biomedical Devices Conference, American Society of Mechanica] Engineering, Newport Beach, CA, 2010, Moderator and Lecturer, Instructional Course Lectures, Advanced Techniques in Cervical Spine Surgery, American Academy of Orthopaedic Surgery, Annual Meeting, San Diego, CA, 2011. Lecturer and La} Instructor, 4® Annual Cervical Spine Decompression and Stabilization Techniques, Cervical Spine Research Society, St. Louis, MO, 2011. Faculty Member, 16™ Annuaj Instructional Course, Cervical Spine Research Society, Phoenix, AZ, 2011. Moderator and Lecturer, Instructional Course Lectures, Advanced Techniques in Cervical Spine Surgery, American Academy of Orthopaedic Surgery, Annual Meeting, San Francisco, CA, 2012. Lecturer and Lab Instructor, 5% Annual Cervical Spine Decompression and Stabilization Techniques, Cervical Spine Res earch Society, St, Louis, MO, 2012, D e bo COMMITTEE POSITIONS HELD: North American Spine Society, Committee on Biologics and Basic Science 2011 — 2013 Board Member, Western Orthopaedic Association 2011-2013 cee CME Committee, Western Orthopaedic Assaciation, 2012 —2013 CME Committee, University of Califomia, Irvine, School Of Medicine, 2009-2013 UC Irvine School of Medicine Senate Assembly Orthopaedic Surgery Representative, 2010-2013 UC Irvine Program in Ethics, Medical Humanities, and Spiritual Care, Associate Faculty 26 EXHIBIT “B” 05-21-19 13:09 FROM- @ Rev. Associates 15624368608 D 1-228 PC002/0010 F-722 NITIN BHATIA, M.D., F.A.C.S. DIPLOMATE, AMERICAN BOARD OF ORTHOPAEDIC SURGERY 525 E. Seaside Way, Ste. 101A Long Beach, CA 90802 Tel. (562) 436-8600 / Fax. (362) 436-8608 MAY 21, 2019 1/0 FORD WALKER HAGGERTY & BEHAR Attn: Mark S. Levine, Esq. One World Trade Center, 27th Floor long Beach, CA 90831-2700 RE: SAYEDEH AMJADI DATE OF EXAM: 05/10/2019 DATE OF INCIDENT: 04/09/2016 INDEPENDENT MEDICAL EXAMINATION Ms. Sayedeh Amjadi is a 35-year-old, right-hand-dominant female. Her birthdate is 05/15/1983. she ig examined today with attention towards an incident that occurred on 04/09/2016. she was accompanied by attorney, David Davidi. Mr. Davidi observed and audio-recorded the evaluation. HISTORY OF INCIDENT AS RELATED BY THE PATIENT: Ms. Amjadi states that she was involved in an accident on 04/09/2016. on the advice of her attorney, she refuses to provide any further information. Her attorney states that this was all provided in previous medical records and depositions. She refuses to describe what kind of accident was involved. She refuses to describe if she was using any safety devices at the time of the incident. She refuses to report whether she lost consciousness. 05-21-"19 13:09 FROM- 9 Rev. Associates 15624368608 ® T-228 P0003/0010 F~722 She refuses to discuss any mechanism of the incident. che refuses to discuss if her body wag struck in the incident. Her attorney does state that the police were summoned to the gcena. An ambulance responded as well. She was transported by ——— ambulance: _ TREATMENT RENDERED (as presented by the patient): she refuses to answer whether she was seen in the emergency room. she refuses to report the names of any doctors she saw. she does state that she had physical therapy. She is unsure if the therapy helped. she refuses to answer what parts of her body were treated. she does state that she had injections. She also had radiofrequency ablation. 5he refuses to answer to what body parts. she has not had any surgery. she said that she is still seeing doctors fox these issues. EMPLOYMENT HISTORY: At the time of the incident, she was employed as an insurance agent. Following the incideat, che was off work for four months. She then returned to work, however, she is not currently working. SUBSEQUENT HISTORY: She refuses to report whether she has been injur ed in any other incidents subsequent to the subject event. PAST MEDICAL HISTORY: Chronic conditions: None. @ 05-21-19 18:10 FROM- D Rev. Asscciates 15624368808 T-228 P0004/0010 F~722 Surgical History: Cosmetic surgery; otherwise, no surgeries in relation to the body parts affected during the subject incident. Current Medications: Current medications related to the subject incident include Robaxin, ibuprofen 800 mg and gabapentin. She : edications—mm ————— Allergies: None. Previous and Subsequent Trauma: Refuses to answer. . SOCIAL HISTORY: She ig single. She has no children. She does not smoke. she does not drink alcohol. CURRENT COMPLAINTS: she currently complains of neck problems. She states that these began after the subject incident. She denies any prior complaints. She states that she has pain in the neck. It will then go into the right shoulder, down the right arm towards the radial elbow, and then into the dorsal aspect of the hand. She also has headaches. She states that the neck pain occurs constantly and daily. It will start in the neck and then go into the right shoulder, arm and hand. She notes that the right shoulder pain began after she underwent a block for the neck pain. She feels weakness in the right arm. She feels numbness in both forearms at night. She localizes the numbness along the ulnar aspect of the forearms. She feels pressure in the mid- neck. She states that the pain is always 10/10. When it gets worse, it will be more than 10+/10 and she wishes she were dead. At night, she notes numbness of the ulnar aspect of the fozearms and hands, bilaterally. She states that elevating her arms causes posterior neck pain. She does not know of anything that makes the pain better. Over the past six wonths, she thinks that these pains have been getting worse. She notes that her right hand and wrist also feel “loose.” She has difficulty doing household chores as well as activities of daily living such as washing her halr. She also notes that she has headaches. These occur two to three times per week. She states that they will stazt after even minimal activity. They go up from the posterior aspect of her head to the right side of her head. 05-21-19 13:10 FROM- D.. Associates 15624368608 ® 1-228 PO005/0010 F-722 She also complains of low back problems. These low back problems began after the subject incident. she feels pain in the low back, more on the right side than the left side, It will then go into what she calls the right hip. She localizes this into the right buttock, greater trochanteric area, and ischium. It then goes down towards the anterior aspect of the right knee. She also feels the pain down ———— th tars? REDE : 2G ght—ecalE and the rh aniele she numbness in these same areas. She denies any left-sided leg symptoms. She relates that her right ankle feels lcose. She feels burning in the midline at approximately LS. She feels occasional popping when she moves her right leg. She feels pain in the right knee. She rates these pains at 10/10. The symptoms are made worse with any activity. She does not know of anything that makes them better. Over the past six months, the symptoms are getting worse. > J PHYSICAL EXAMINATION: SPINAL EXAMINATION She stands with a normal posture. There is severe tenderness to palpation with even minimal pressure on the midline at the cervicothoracic junction as well as the right posterior superior iliac spine, right greater trochanter, right piriformis, and lumbosacral junction. she walks with a normal gait, except she complains of right buttock pain, right greater trochanteric pain, right iliotibial band pain as well as anterior right knee pain, During the toe walk exam, she takes a few steps on her toes and then says that she feela weak in the right leg and ie afraid of falling and she stops. She declines doing heel walking due to fear of falling. There is no evidence of gross ataxia. She does complain of right greater trochanteric pain with heel-toe testing, At this point, she says that she will get some left greater trochanteric pain due to overcompensating with the left to protect the right side. feelg— - -- 05-21-"19 13:10 FROM MEM Rev, Associates 15624368608 ® 1-228 POO0B/0ON0 F—722 Range of Motion (in dagxraes): Cervical: Forward Flexion 40 . ——— .-— Extension _ 50 a rs gp Right Rotation 50 Left Rotation 50 Right lateral bending 40 Left lateral bending 40 She complains of posterior neck pain at the cervicothoracic junction with rotation, bilaterally. She ‘feels pain in the right trapezius muscle with left-aided bending. That pain in the right trapezius muscle will them go towards the right shoulder. Lumbar: Forward Flexion 50 Extension 0 Right Lateral Bending 30 Left Lateral Bending 30 Motor: The patient has 5/5 strength with the bilateral deltoids, biceps, triceps, wrist flexors and intrinsic hand wuscles. She also has 5/5 strength of the bilateral hip flexors, quadriceps, ERL, tibialis anterior and gastroc-soleus complex. she has diffuse ratcheting in the bilateral upper and lower extremities. Her attorney states that this is a tremor, however, the tremor is not present during any other portion of the examination or the history. Reflaxes: Right Left Biceps 2+ 2+ Triceps 2+ 2+ Brachioradialis 2+ 2+ Quadriceps 2+ 2+ Achilles 2+ 2+ 05-21-" 18 13:10 FROM- D Rev, Associates 15624368608 ® T-228 P0007/0010 F-722 Sensozxy: She has decreased sensation globally in the right upper extremity and right lower extremity, in a non-dermatomal pattern. Tegts: Spurling’s signs are negative, bilaterally. ° Hoffman’s test is negative, bilaterally. Finger escape @ign is negative, bilaterally. Clonus: Zero beats bilaterally and symmetric. Straight leg raising is negative, bilaterally. BIPS Hip Range of Motion (in degrees): Right Left Internal Rotation 20 20 External Rotation 20 20 Internal and external rotation do not produce groin pain. Negative Faber’s testing, bilaterally. She does complain of right anterior knee pain with right hip range of motion testing and right hip Faber’s testing. SHOULDERS Range of Motion: Right Left Forward Flexion: 90 20 Abduction: Shoulder 160 External Rotation: 70 70 Internal Rotation: Ilium T8 She complains of posterior neck pain at the cervicothoracic junction with forward flexion of the shoulders. She complains of right shoulder pain with abduction. r i m o f mv . — — 05-21-19 13:10 FROM- D.. Associates 156243688608 ® 1-228 POO08/0010 F-722 Right shoulder nonprovocative motion: She complains of elbow pain at the area where I am supporting her right elbow as well as proximal humerus pain. Otherwise, negative shoulder impingement, apprehension and crossed-arm adduction testing on the right. Negative shoulder impingement, apprehension and crossed-arm —— --——adduction—testingontheleft—— me There is tenderness to palpation over the right knee medial and lateral jointline and patellofemoral joint. Otherwise, the knee exams are normal, bilaterally, with no effusion bilaterally. Knee range of motion is 0-120 degrees, bilaterally. The knees are stable, bilaterally. Negative McMurray’s sign, bilaterally. Negative anterior drawer and posterior drawer, bilaterally. ANKLES pDorsiflexion bilaterally to 20 degrees. Plantarflexion bilaterally to 30 degrees. There is tenderness to palpation over the right foot, just dis tal to the lateral malleoli, in the area of the peroneal tendon s. She states that this tenderness will then radiate up to her anteri or knee. Thexe is no evidence of tenderness to palpation ove r the ankles, bilaterally. The ankles are stable, bilaterally. No effusion, bilaterally. JAMAR DYNAMOMETER GRIP TESTING (in pounds) Right: 5, 1, 3. She complains of radial forearm pain during right-sided testing. Left: 40, 45, 40. She notes that holding the grip t est device causes posterior neck pain. DISCUSSION: Ms. Amjadi has broad areas of complaints and multiple, non- organic, non-dermatomal findings. Due to her lack of cooperation with the examination, her records/iwmaging will need to be reviewed in order to come to any conclusions regarding the inj uries that she sustained as a result of the subject event. 05-21-18 13:10 FROM Q Rev. Associates 15624388608 D T-228 P000S/0010 F-72p If you have further questions pertaining to this matter, please do not hesitate to contact this office. Sincerely, - Diplomate, Awerican Board of Orthopaedic Surgery Fellow, American College of Surgeons Chairman Dept. of Oxthopaedic Surgery Univ. of California, Irvine NB:le EXHIBIT B © 0 N N O O a A~A W N = N N N N N NN NM N M N N = =o oo =o eo o F = «ow = = 0 ~N OO O h & W N = = © © 0 ~ N O O Oh is WO N =2 © Kevin R. Jolly, State Bar No. 172328 Leah Berry, State Bar No. 196505 Kris Amundsen, State Bar No. 325504 JOLLY BERRY LAW 27762 Vista Del Lago, Suite A-11 Mission Viejo, CA 92626 E-Mail: kj@jollyberrylaw.com Phone: (94) 515-9000 Fax No.: (949) 415-2342 Attorneys for Plaintiff: Sayedeh Sahba Amjadi SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF ORANGE — CENTRAL JUSTICE CENTER SAYEDEH SAHBA AMJAD, ) Case No: 30-2018-00976542-CU-PA-CJC a } Consolviatod w/ Case No. 30-2018- Plaintiff, 00978077-CU-PA-CJC] UNLIMITED ASSIGNED FOR ALL PURPOSES TO: HON. DEREK W. HUNT Vv. JERROD WEST BROWN; MARK HOWERTON; SCOTT MATTHEW | MCMASTERS; and DOES 1 through Dept: C23 20, inclusive, Date Action Filed: February 28, 2018 Defendants. Trial Date: Not Set SHABNAM SHAHROKSHAHI, ) PLAINTIFF SAYEDEH SAHBA AMJADI'S NOTICE OF TAKING EXPERT Plaintiff, DEPOSITION OF NITIN N. BHATIA, MD. AND PRODUCTION OF DOCUMENTS Vv. AND MATERIAL THINGS AT LEAST 3 BUSINESS DAYS BEFORE TRIAL. MARK J. HOWERTON; JERROD WEST BROWN; and DOES 1 through 50, inclusive, Defendants. TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE THAT Plaintiff, Sayedeh Sahba Amjadi, through her attorney of record, JOLLY BERRY LAW, will take the videotaped deposition of Defendant Jerrod West Brown's retained expert witness, NITIN N. BHATIA, M.D. on -1- PLAINTIFF'S NOTICE OF DEPOSITION OF NITIN N. BHATIA @@ OO ~N OO Hh O N = N N N NN NN M N N N = e d w d e d =m m d m h m k =m w h BD N B RX R U V U R N A N E ES I a r p 2 3 S January 2, 2019, at 10:00 a.m., JOLLY BERRY LAW, 27762 Vista Del Lago, Ste. A- 11, Mission Viejo, CA 92692, upon oral examination before any certified shorthand court reporter who is present at the specified time and place and under the provisions of Section 2025.010 et. seq. of the Code of Civil Procedure. PLEASE NOTE that the Deponent and his attorney jointly and severally, are responsible for any cancellation fees charged (including, but not limited to, the court reporter, videographer, and/or interpreter), if notice of cancellation is not provided to the noticing party, in writing, at least three (3) business days prior to the deposition date noticed herein. NOTICE IS FURTHER GIVEN that pursuant to the provisions of Code of Civil Procedure Sections 2025, 2034.410, and 2034.415 the deponent is required to produce the following documents for inspection and copying at least 3 business days prior to the date said deposition is noticed for. The above-described deponent shall bring and produce at the deposition, at the time and place set out above, the following writing(s) and/or tangible thing(s): 1. The expert's complete file relating to this litigation, including all materials and documents which the expert has reviewed in anticipation of, or in preparation for deposition; 2. Current resume or curriculum vitae; 3. A complete list of all works presented by the expert at professional meetings or seminars; 4. ldentification of all cases the expert has testified as an expert in the last ten years, including but not limited to case name, name of attorney who retained the expert and name of party on behalf the expert testified; 5. All writings (as that term is defined in California Evidence Code §250), including but not limited to books, documents, works, texts, studies, treatises, articled, code, regulations, statutes, upon which the expert has relied to any degree, in forming any opinion, evaluation or judgement relating to this litigation; Di PLAINTIFF'S NOTICE OF DEPOSITION OF NITIN N. BHATIA © OO ~N O O Oa AA O N = N N N N N N N NM N N = wo oo o F = eo wo w= = = 0 ~N OO O0 1 Ah W N = O © O0 0 ~N 0 6 &d& O N =2 O . All writings, as that term is defined in California Evidence Code §250, including but not limited to written reports, draft reports, report outlines, or other writings which reflect any of the opinions of the expert relating to this litigation; . All writings, as that term is defined in California Evidence Code §250, regarding the instant action, in the possession, custody or control of the expert, whether or not relied upon by the expert in rendering an opinion; . All writings, as that term is defined in California Evidence Code §250, to or from any agent, principal officer, employee, attorney, accountant, investigator or any other person or entity acting on behalf of Defendant Jerrod West Brown, including but not limited to reports, letters, memoranda, notes or the like; . All notes and records of communication of any kind, with counsel and/or the designating parties’ representatives, relating to this litigation; 10. All letters of engagements or contracts for service; 11. All writings, as that term is defined in California Evidence Code §250, that relate to the date and hours expended by said expert regarding this litigation; 12. All time records and billing records for the expert's service in this litigation; and 13. All correspondence to and from counsel for JERROD WEST BROWN; and 14. All documents which the expert has prepared in connection with any inspection, research, investigation, testing or examination of the subject matter of this action, including reports, notes, correspondence, memoranda, photos, charts, video tapes, motion picture films or diagrams, subrosa material, whether or not the expert intends to rely on these documents in connection with his conclusions, opinions or testimony at trial. NOTICE IS FURTHER GIVEN that Plaintiff SAYEDEH SAHBA AMJADI intends to reserve the right to use at trial, the video recording of the deposition testimony, under Section §2025.620(d) of the Code of Civil Procedure. NOTICE IS HEREBY GIVEN that if the expert fails to produce all tangible and intangible evidence falling within the scope of this notice of deposition and demand for -3- PLAINTIFF'S NOTICE OF DEPOSITION OF NITIN N. BHATIA © oO N N oOo Oa »~A W O N =~ N O N N N N N NN NN NN ND NN @ @Q a QQ QQ OO a a o a = 0 N N oO o ag A O W N 2 O O OW 00 NN oO O b W N =a Oo production of documents at least 3 days prior to the deposition plaintiff Savedeh Sahba Amjadi will move the Court for an order precluding Dr. Bhatia from testifying at trial and/or excluding all such tangible and intangible evidence. DATED: December 12, 2019 JOLLY BERRY LAW By: Kevin R. Jolly, Esq. / Leah Berry, Esq. Kris Amundsen, Esq. Attorney for Plaintiff Sayedeh Sahba Amjadi 4- PLAINTIFF'S NOTICE OF DEPOSITION OF NITIN N. BHATIA © 0 N N oO Oo A W N = N O N D N N N N NN NN N N NN NN 2 Q Q QQ 2 2 wa =a =D = a a 0 ~N oO RA W N S O WwW N O O E E N N ~ ~ OO PROOF OF SERVICE (Business Practice to Entrust Deposit to Others California Code of Civil Procedure § 1013 and 1013a) (Amjadi vs. Brown, et al) I, Ruhani Patel, declare as follows: Ts | am over the age of 18 and not a party to this action. My business address is 27762 Vista del Lago, Suite A-11, Mission Viejo, CA, 92692, which is located in Orange County, the county where this mailing occurred. 2. | am readily familiar with the business practice at my place of business for collection and processing of correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is deposited with the United States Postal Service that same day in the ordinary course of business. 3 On December 12, 2019, at my place of business at Mission Viejo, California, the document described as PLAINTIFF SAYEDEH SAHBA AMJADI'S NOTICE OF TAKING EXPERT DEPOSITION OF NITIN N. BHATIA, MD. AND PRODUCTION OF DOCUMENTS AND MATERIAL THINGS AT LEAST 3 BUSINESS DAYS BEFORE TRIAL was placed for collection and mailing following ordinary business practices for deposit in the United States Postal Service in a sealed envelope, with postage fully prepaid, addressed to: Attorney(s) for: Defendant, JERROD WEST BROWN Richard S. Gower, Esq. INGLIS, GOWER & WARRINER, LLP 500 S. Grand Avenue, Suite 1400 Los Angeles, CA 90071 | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed December 12, 2019, at Mission Viejo, California. Ruhani Patel” -5- ~ PROOF F SERVICE EXHIBIT C Ww 0 N N OO 0 A W N = N N NBN NN NM N N N N N = co «o oo o oo oo = = = 0 N N OO 0 As W N = O © N R W NN = 0 Kevin R. Jolly, State Bar No. 172328 Leah Berry, State Bar No. 196505 Kris Amundsen, State Bar No. 325504 JOLLY BERRY LAW 27762 Vista Del Lago, Suite A-11 Mission Viejo, CA 92626 E-Mail: ki@jollyberrylaw.com Phone: (649) 515-8000 Fax No.: (949) 415-2342 Attorneys for Plaintiff: Sayedeh Sahba Amjadi SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF ORANGE — CENTRAL JUSTICE CENTER SAYEDEH SAHBA AMJAD, Case No: 30-2018-00976542-CU-PA-CJC . [Consolidated w/ Case No. 30-2018- Plaintiff, 00978077-CU-PA-CJC] UNLIMITED V. ASSIGNED FOR ALL PURPOSES TO: JERROD WEST BROWN; MARK HON. DEREK W. HUNT HOWERTON; SCOTT MATTHEW MCMASTERS; and DOES 1 through Dept: C23 20, inclusive, Date Action Filed: February 28, 2018 Defendants. Trial Date: Not Set SHABNAM SHAHROKSHAHI, PLAINTIFF SAYEDEH SAHBA AMJADI'S AMENDED NOTICE OF Plaintiff, TAKING EXPERT DEPOSITION OF NITIN N. BHATIA, MD. AND V. PRODUCTION OF DOCUMENTS AND MATERIAL THINGS AT LEAST 3 MARK J. HOWERTON; JERROD BUSINESS DAYS BEFORE TRIAL. WEST BROWN; and DOES 1 through 50, inclusive, Defendants. a p ” ! TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE THAT Plaintiff, Sayedeh Sahba Amjadi, through her attorney of record, JOLLY BERRY LAW, will take the videotaped deposition of Defendant Jerrod West Brown's retained expert witness, NITIN N. BHATIA, M.D. on -1- PLAINTIFF'S NOTICE OF DEPOSITION OF NITIN N. BHATIA © 0 N N oO O h O N = N N N N N NN NN N N M P N AQ @ ob o F o o «o b o b =o = = WO ~N O O O h iH W N = O © 00 ~N OO O s W O N = OO January 16, 2020, at 9:00 a.m., at 555 E. Ocean Blvd, Suite 500 Long Beach, CA 90802, upon oral examination before any certified shorthand court reporter who is present at the specified time and place and under the provisions of Section 2025.010 et. seq. of the Code of Civil Procedure. PLEASE NOTE that the Deponent and his attorney jointly and severally, are responsible for any cancellation fees charged (including, but not limited to, the court reporter, videographer, and/or interpreter), if notice of cancellation is not provided to the noticing party, in writing, at least three (3) business days prior to the deposition date noticed herein. NOTICE IS FURTHER GIVEN that pursuant to the provisions of Code of Civil Procedure Sections 2025, 2034.410, and 2034.415 the deponent is required to produce the following documents for inspection and copying at least 3 business days prior to the date said deposition is noticed for. The above-described deponent shall bring and produce at the deposition, at the time and place set out above, the following writing(s) and/or tangible thing(s): 1. The expert's complete file relating to this litigation, including all materials and documents which the expert has reviewed in anticipation of, or in preparation for deposition; 2. Current resume or curriculum vitae; 3. A complete list of all works presented by the expert at professional meetings or seminars; 4. Identification of all cases the expert has testified as an expert in the last ten years, including but not limited to case name, name of attorney who retained the expert and name of party on behalf the expert testified; 5. All writings (as that term is defined in California Evidence Code §250), including but not limited to books, documents, works, texts, studies, treatises, articled, code, regulations, statutes, upon which the expert has relied to any degree, in forming any opinion, evaluation or judgement relating to this litigation; . De PLAINTIFF'S NOTICE OF DEPOSITION OF NITIN N. BHATIA © 0 N N O O Oh A O N = N N N N N N N N N N N o& a o b ob eo & =o «oo eo = 0 ~N O&O OO A O N a2 O O © 00 ~N O O O F & O N = O° 6. All writings, as that term is defined in California Evidence Code §250, including but not limited to written reports, draft reports, report outlines, or other writings which reflect any of the opinions of the expert relating to this litigation; 7. All writings, as that term is defined in California Evidence Code §250, regarding the instant action, in the possession, custody or control of the expert, whether or not relied upon by the expert in rendering an opinion; 8. All writings, as that term is defined in California Evidence Code §250, to or from any agent, principal officer, employee, attorney, accountant, investigator or any other person or entity acting on behalf of Defendant Jerrod West Brown, including but not limited to reports, letters, memoranda, notes or the like; 9. All notes and records of communication of any kind, with counsel and/or the designating parties’ representatives, relating to this litigation; 10. All letters of engagements or contracts for service; 11. All writings, as that term is defined in California Evidence Code §250, that relate to the date and hours expended by said expert regarding this litigation; 12. All time records and billing records for the expert's service in this litigation; and 13. All correspondence to and from counsel for JERROD WEST BROWN; and 14. All documents which the expert has prepared in connection with any inspection, research, investigation, testing or examination of the subject matter of this action, including reports, notes, correspondence, memoranda, photos, charts, video tapes, motion picture films or diagrams, subrosa material, whether or not the expert intends to rely on these documents in connection with his conclusions, opinions or testimony at trial. NOTICE IS FURTHER GIVEN that Plaintiff SAYEDEH SAHBA AMJADI intends to reserve the right to use at trial, the video recording of the deposition testimony, under Section §2025.620(d) of the Code of Civil Procedure. NOTICE IS HEREBY GIVEN that if the expert fails to produce all tangible and intangible evidence falling within the scope of this notice of deposition and demand for -3- PLAINTIFF'S NOTICE OF DEPOSITION OF NITIN N. BHATIA OW 00 N N oO Oo A w O N = N O N O N N N NN NN NN N N = 2 @ o - o o = = =a oe 0 N N oO O o h W O N 2 O W N O O h h , W N ~~ Oo production of documents at least 3 days prior to the deposition plaintiff Savedeh Sahba Amjadi will move the Court for an order precluding Dr. Bhatia from testifying at trial and/or excluding all such tangible and intangible evidence. DATED: January 14, 2020 JOLLY BERRY LAW By: fio KH Kevin R. Joly, Esq. Leah Berry, Esq. Kris Amundsen, Esq. Attorney for Plaintiff Sayedeh Sahba Amijadi llc PLAINTIFF'S NOTICE OF DEPOSITION OF NITIN N. BHATIA Ww 0 ~N O O 0 A O N = N N N N N N N NM N N N D DN o& ao o f wb = w f wo = = = 0 ~N & O O & W O N =2 © WW 0 ~N OO A E N = O PROOF F SERVICE (Business Practice to Entrust Deposit to Others California Code of Civil Procedure § 1013 and 1013a) (Amjadi vs. Brown, et al) I, Ruhani Patel, declare as follows: 1. | am over the age of 18 and not a party to this action. My business address is 27762 Vista del Lago, Suite A-11, Mission Viejo, CA, 92692, which is located in Orange County, the county where this mailing occurred. 2. | am readily familiar with the business practice at my place of business for collection and processing of correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is deposited with the United States Postal Service that same day in the ordinary course of business. 3. On January 14, 2020, at my place of business at Mission Viejo, California, the document described as PLAINTIFF SAYEDEH SAHBA AMJADI’S AMENDED NOTICE OF TAKING EXPERT DEPOSITION OF NITIN N. BHATIA, MD. AND PRODUCTION OF DOCUMENTS AND MATERIAL THINGS AT LEAST 3 BUSINESS DAYS BEFORE TRIAL was placed for collection and mailing following ordinary business practices for deposit in the United States Postal Service in a sealed envelope, with postage fully prepaid, addressed to the address listed below. 4. On January 14, 2020, | also served the above mentioned document by facsimile to the persons listed below. | did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. 1111 1111 1111 1111 1111 -5- PROOF OF SERVICE © 0 ~N oO Oo Ah W O N = N N N NN N N NM N N N B N «& =o oO 2 =o wo «eo «wo «= = 0 ~N OO Oh & W N 2 O O OW 0 ~N O O O r ha O N a2 OO Attorney(s) for: Defendant, JERROD WEST BROWN Richard S. Gower, Esq. INGLIS, GOWER & WARRINER, LLP 500 S. Grand Avenue, Suite 1400 Los Angeles, CA 80071 F: (213) 622-2857 Attorney(s) for: Non Party Witness, Dr. Nitin Bhatia Eliot B Guterson, Esq. 10940 Wilshire Blvd., 16% floor Los Angeles CA 90024 F: (310) 443-4198 | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed January 14, 2020, at Mission Viejo, California. Lhe. Ruhani Patel -6- PROOF OF SERVICE © 00 N N oO Oa A O N = N O N N N N N DN DND N DN MN D N QQ @Q 2 @O @ 2 w d w d o w ow 0 N N O O Og bh W O N 2 O O O W 00 N N oO Oo b E W O N ~~ Oo PROOF OF SERVICE (Business Practice to Entrust Deposit to Others California Code of Civil Procedure § 1011; 1013(A)(1) & (3) (Amjadi vs. Brown, et al) I, Ruhani Patel, declare as follows: 1 | am over the age of 18 and not a party to this action. My business address is 27762 Vista del Lago, Suite A-11, Mission Viejo, CA, 92692, which is located in Orange County, the county where this mailing occurred. 2. | am readily familiar with the business practice at my place of business for collection and processing of correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is deposited with the United States Postal Service that same day in the ordinary course of business. 9 On January 21, 2020, at my place of business at Mission Viejo, California, the document described as PLAINTIFF'S MOTION IN LIMINE #1 TO PRECLUDE NITIN BHATIA FROM TESTIFYING AT TRIAL was transmitted to the below email address and placed for collection and mailing following ordinary business practices for deposit in the United States Postal Service in a sealed envelope, with postage fully prepaid, addressed to: Attorney(s) for: Defendant, JERROD WEST Attorney(s) for: Plaintiff, SAYEDEH SABHA BROWN AMJADI RGower@ilglwaw.com joe@accidentlawyersfirm.com Richard S. Gower, Esq. Joseph Nazarian, Esq. INGLIS, GOWER & WARRINER, LLP Accident Lawyers Firm 500 S. Grand Avenue, Suite 1400 2901 W. Coast Highway, Suite 200 Los Angeles, CA 90071 Newport Beach, CA 92663 | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed January 21, 2020, at Mission Viejo, California. if Ruhani Patel -3- PROOF OF SERVICE
