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Filing # 196591443 E-Filed 04/19/2024 02:27:30 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR
OSCEOLA COUNTY, FLORIDA
MAUREEN M. HENTZ, individually and as
guardian for BRIAN HENTZ, her incapacitated
Husband,
Plaintiff, CASE NO.: 2017CA000155AN
v.
KIMBALL TRANSPORTATION, INC., a Florida
for profit corporation, RYAN KIMBALL, BRIAN
KIMBALL, and COUSINS LOGISTICS, INC.,
Defendants.
PLAINTIFF’S EXHIBIT LIST
Plaintiff, MAUREEN M. HENTZ, individually and as a guardian for BRIAN HENTZ, her
incapacitated Husband, by and through the undersigned counsel and pursuant to the Florida Rules
of Civil Procedure, hereby gives notice that the following may be used as exhibits at the trial of
this cause:
“SE” means admissible into evidence by agreement of the parties. “SA” means stipulated
to authenticity only, with objections reserved for relevancy. “O” means objected to.
NO. PLAINTIFF’S EXHIBITS SE/SA/O ID EVID.
PARTY PRODUCTION
1. Photographs and video of the crash scene and vehicles involved.
2. Photographs of the vehicles taken on the day of the crash and
after during the subsequent investigation and inspection.
3. Photographs and videos taken of the vehicles and scene after
the crash.
4. Photographs/videos of Brian Hentz prior to the crash.
5. Photographs/videos of Brian Hentz after the crash.
6. Statements taken of witnesses to the crash.
7. NFIRS and EMS records from first responders to the crash.
Promotional materials, operator’s manuals, and documents
8.
relevant to the purchase of and available options/equipment for
the 2005 Peterbilt tractor involved in the subject crash.
9. All Kimball produced policy manuals, handbooks, standards,
materials, etc.
10. All materials relevant to the inspection, maintenance and repair
for the Peterbilt tractor involved in the subject crash.
All driver qualification, supervision, monitoring, training,
11. discipline, employment and other records from Kimball
Transportation, Inc. pertaining to Ryan Kimball and Brian
Kimball.
12. Ryan Kimball’s driving record.
13. News footage of the crash.
14. All records and documentation obtained pertaining to the
inspection of the 2005 Peterbilt tractor in question.
15. All Kimball training materials whether provided to Ryan
Kimball or not.
16. All logs, GPS monitoring and other electronic data from the 2005
Peterbilt tractor in question.
17. 911 Call Logs and Audio Files of the same
FMCSA Data and Information/CDL Safety/Applicable
Florida Laws
18. Applicable portions of the Florida CDL Driver’s Handbook.
Applicable portions of the Federal Motor Carrier Safety
19.
Regulations.
Applicable portions of the US DOT Preventable Accident
20.
Manual and ATA Accident Preventability manuals.
Federal Motor Carrier Safety Administration SaferSys
information, printouts, Company Snapshot, safety violations,
21.
audits, compliance reviews, data for Defendant Kimball
Transportation, Inc.
22. Federal Motor Carrier Safety Administration Carrier
Compliance Safety Manual, safety management cycle
information, and other free information available to all motor
carriers including Defendant Kimball Transportation, Inc.
Federal Motor Carrier Safety Measurement System information,
23.
printouts, safety ratings, and out of service data for Kimball
Transportation, Inc.
JJ Keller Driving Training Manual, training videos, and other
24.
industry training materials relevant to the facts of this case.
25. Alice Adams Delmar Tractor Trailer Driver Training Manual
materials relevant to the facts of this case.
26. National Safety Council videos, and other truck driver training
materials relevant to the facts of this case.
27. The Smith Systems 5 Keys and other defensive driving
materials.
28. Applicable Florida Traffic Statutes.
Medical and Billing Records
29. Medical and billing records from: Osceola Regional Medical
Center
30. Medical and billing records from: Neuro Restorative Florida
31. Medical and billing records from: NeuLife Rehabilitation
32. Medical and billing records from: Cooper University Hospital
33. Medical and billing records from: Centra Comprehensive
Psychotherapy and Psychiatric Services
34. Medical and billing records from: Jefferson Health
35. Medical and billing records from: South Jersey Radiology
36. Medical and billing records from: Advanced Cardiology of
South Jersey
37. Medical and billing records from: Clinical Neuropsychology
Associates
38. Medical and billing records from: Bancroft Neuro Rehab
39. Medical and billing records from: Neuro Restorative New Jersey
40. Pharmacy Records: All pharmacy records relevant to the
treatment of Plaintiff
41. Past Medical Bills Summary
42. Summary of Anticipated Future Costs from Roger Huckfeldt,
M.D., CLCP
Any and all Diagnostic studies, data, and films of MRI’s, CT
43.
Scans, X-Rays, Fluoroscopic Studies from the medical providers
disclosed.
Witnesses
44. Deposition transcript with Exhibits in this case: Corporate
Representative of Kimball Transportation, Inc.
45. Deposition transcript with Exhibits in this case: Ryan Kimball
46. Deposition transcript with Exhibits in this case: Brian Kimball
47. Deposition transcript with Exhibits in this case: Jason Kimball
48. Deposition transcript with Exhibits in this case: Trooper CC
Grant
49. Deposition transcript with Exhibits in this case: EMT/Paramedic
Jose Marmolejo
Retained Experts
Roger Huckfeldt, M.D., CLCP
50. Records and materials provided to Dr. Huckfeldt for review and
consideration and produced with his expert file.
51. Any and all materials produced in the expert file of Roger
Huckfeldt.
52. Deposition Transcript and Exhibits in this case: Roger
Huckfeldt.
53. Demonstrative Exhibits needed to explain and/or illustrate his
opinions.
Syed Asad, M.D.
54. Records and materials provided to Dr. Asad for review and
consideration and produced with his expert file.
55. Any and all materials produced in the expert file of Dr. Asad.
56. Deposition Transcript and Exhibits in this case: Dr. Asad.
57. Demonstrative Exhibits needed to explain and/or illustrate his
opinions.
Brian Pfeifer, Ph.D., P.E.
58. Records and materials provided to Dr. Pfeifer for review and
consideration and produced with his expert file.
59. Any and all materials produced in the expert file of Brian Pfeifer.
60. Deposition Transcript and Exhibits in this case: Brian Pfeifer.
61. Demonstrative Exhibits needed to explain and/or illustrate his
opinions.
Adam Grill
62. Records and materials provided to Adam Grill for review and
consideration and produced with his expert file.
63. Any and all materials produced in the expert file of Adam Grill.
64. Deposition Transcript and Exhibits in this case: Adam Grill.
65. Demonstrative Exhibits needed to explain and/or illustrate his
opinions.
R. Scott King, BSME, CFEI
66. Records and materials provided to Scott King for review and
consideration and produced with his expert file.
67. Any and all materials produced in the expert file of Scott King.
68. Deposition Transcript and Exhibits in this case: Scott King.
69. Demonstrative Exhibits needed to explain and/or illustrate his
opinions.
Miscellaneous and Demonstrative
70. All deposition transcripts and exhibits for depositions not yet
taken in this case, not otherwise objected to by Plaintiff.
71. All video deposition testimony taken in this case, not otherwise
objected to by Plaintiff.
Any information or documentation required to establish
72.
curriculum vitae of Plaintiff’s experts, or to establish him or her
as an expert.
73. Any exhibit necessary for rebuttal or impeachment purposes.
74. All prior testimony and financial bias documents of any
disclosed defense expert.
All references, cited authorities, texts, articles, books, videos,
75. studies, etc. referenced in the reports or deposition of any
disclosed defense or plaintiff’s expert, timely produced and not
otherwise objected to by Plaintiff.
76. Visual aids prepared by Plaintiff’s experts that will be used to
explain and highlight their anticipated testimony.
Any and all responses to discovery by any party or former
77. party to this lawsuit timely produced and not otherwise
objected to by Plaintiff.
Any and all responses to Requests for Admissions by any
78. party or former party to this lawsuit timely produced and
not otherwise objected to by Plaintiff.
Any and all exhibits and documents listed on any other party's
79.
exhibit/document list or disclosure, timely produced and not
otherwise objected to by Plaintiff.
Any and all affidavits signed by any witness or party to this
80.
matter, timely produced and not otherwise objected to by
Plaintiff.
All documents and items reviewed by plaintiff and defense
81. experts in this matter, timely produced and not otherwise
objected to by Plaintiff.
82. All blowups, enlargements, etc. of any of the above exhibits.
83. Life mortality table(s).
Medical illustrations, graphics, models, videos of Plaintiff’s
surgeries and medical treatments showing procedure and/or
84.
injuries, colorized PowerPoint slides and/or blowups
demonstrating same and other demonstrative aids (currently
undetermined).
Further discovery is expected to reveal other exhibits or evidence which may be used by
Plaintiff at trial. This fact may necessitate future amendments to Plaintiff’s Exhibit List. Plaintiff
reserves the right to amend this list to include additional exhibits that may come to light,
were mistakenly omitted, or which may be revealed through ongoing discovery in this
matter.
THE TRUCK ACCIDENT LAW FIRM
/s/ Joseph V. Camerlengo, B.C.S.
Joseph V. Camerlengo, B.C.S.
Florida Bar No.: 008192
Jessica L. Lanifero, Esq.
Florida Bar No. 021062
1200 Riverplace Blvd, Suite 902
Jacksonville, Florida 32207
Telephone: (904) 306-9220
Facsimile: (904) 306-9221
jvc@truckcrashlaw.com
team@truckcrashlaw.com
and
ARONBERG, KOUSER, SNYDER
& LINDERMANN, P.A.
Daniel K. Snyder, admitted pro hac vice
430 Route 70 West
Cherry Hill, New Jersey 08002
(856) 429-1700
dsnyder@akplaw.net
Counsel for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 19th day of April, 2024, a true and correct copy of the
foregoing has been filed with the Court via the Florida Courts E-Filing Portal which will send an
electronic copy to all counsel of record.
/s/ Joseph V. Camerlengo
Attorney
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Filing # 196591443 E-Filed 04/19/2024 02:27:30 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA MAUREEN M. HENTZ, individually and as guardian for BRIAN HENTZ, her incapacitated Husband, Plaintiff, CASE NO.: 2017CA000155AN v. KIMBALL TRANSPORTATION, INC., a Florida for profit corporation, RYAN KIMBALL, BRIAN KIMBALL, and COUSINS LOGISTICS, INC., Defendants. PLAINTIFF’S EXHIBIT LIST Plaintiff, MAUREEN M. HENTZ, individually and as a guardian for BRIAN HENTZ, her incapacitated Husband, by and through the undersigned counsel and pursuant to the Florida Rules of Civil Procedure, hereby gives notice that the following may be used as exhibits at the trial of this cause: “SE” means admissible into evidence by agreement of the parties. “SA” means stipulated to authenticity only, with objections reserved for relevancy. “O” means objected to. NO. PLAINTIFF’S EXHIBITS SE/SA/O ID EVID. PARTY PRODUCTION 1. Photographs and video of the crash scene and vehicles involved. 2. Photographs of the vehicles taken on the day of the crash and after during the subsequent investigation and inspection. 3. Photographs and videos taken of the vehicles and scene after the crash. 4. Photographs/videos of Brian Hentz prior to the crash. 5. Photographs/videos of Brian Hentz after the crash. 6. Statements taken of witnesses to the crash. 7. NFIRS and EMS records from first responders to the crash. Promotional materials, operator’s manuals, and documents 8. relevant to the purchase of and available options/equipment for the 2005 Peterbilt tractor involved in the subject crash. 9. All Kimball produced policy manuals, handbooks, standards, materials, etc. 10. All materials relevant to the inspection, maintenance and repair for the Peterbilt tractor involved in the subject crash. All driver qualification, supervision, monitoring, training, 11. discipline, employment and other records from Kimball Transportation, Inc. pertaining to Ryan Kimball and Brian Kimball. 12. Ryan Kimball’s driving record. 13. News footage of the crash. 14. All records and documentation obtained pertaining to the inspection of the 2005 Peterbilt tractor in question. 15. All Kimball training materials whether provided to Ryan Kimball or not. 16. All logs, GPS monitoring and other electronic data from the 2005 Peterbilt tractor in question. 17. 911 Call Logs and Audio Files of the same FMCSA Data and Information/CDL Safety/Applicable Florida Laws 18. Applicable portions of the Florida CDL Driver’s Handbook. Applicable portions of the Federal Motor Carrier Safety 19. Regulations. Applicable portions of the US DOT Preventable Accident 20. Manual and ATA Accident Preventability manuals. Federal Motor Carrier Safety Administration SaferSys information, printouts, Company Snapshot, safety violations, 21. audits, compliance reviews, data for Defendant Kimball Transportation, Inc. 22. Federal Motor Carrier Safety Administration Carrier Compliance Safety Manual, safety management cycle information, and other free information available to all motor carriers including Defendant Kimball Transportation, Inc. Federal Motor Carrier Safety Measurement System information, 23. printouts, safety ratings, and out of service data for Kimball Transportation, Inc. JJ Keller Driving Training Manual, training videos, and other 24. industry training materials relevant to the facts of this case. 25. Alice Adams Delmar Tractor Trailer Driver Training Manual materials relevant to the facts of this case. 26. National Safety Council videos, and other truck driver training materials relevant to the facts of this case. 27. The Smith Systems 5 Keys and other defensive driving materials. 28. Applicable Florida Traffic Statutes. Medical and Billing Records 29. Medical and billing records from: Osceola Regional Medical Center 30. Medical and billing records from: Neuro Restorative Florida 31. Medical and billing records from: NeuLife Rehabilitation 32. Medical and billing records from: Cooper University Hospital 33. Medical and billing records from: Centra Comprehensive Psychotherapy and Psychiatric Services 34. Medical and billing records from: Jefferson Health 35. Medical and billing records from: South Jersey Radiology 36. Medical and billing records from: Advanced Cardiology of South Jersey 37. Medical and billing records from: Clinical Neuropsychology Associates 38. Medical and billing records from: Bancroft Neuro Rehab 39. Medical and billing records from: Neuro Restorative New Jersey 40. Pharmacy Records: All pharmacy records relevant to the treatment of Plaintiff 41. Past Medical Bills Summary 42. Summary of Anticipated Future Costs from Roger Huckfeldt, M.D., CLCP Any and all Diagnostic studies, data, and films of MRI’s, CT 43. Scans, X-Rays, Fluoroscopic Studies from the medical providers disclosed. Witnesses 44. Deposition transcript with Exhibits in this case: Corporate Representative of Kimball Transportation, Inc. 45. Deposition transcript with Exhibits in this case: Ryan Kimball 46. Deposition transcript with Exhibits in this case: Brian Kimball 47. Deposition transcript with Exhibits in this case: Jason Kimball 48. Deposition transcript with Exhibits in this case: Trooper CC Grant 49. Deposition transcript with Exhibits in this case: EMT/Paramedic Jose Marmolejo Retained Experts Roger Huckfeldt, M.D., CLCP 50. Records and materials provided to Dr. Huckfeldt for review and consideration and produced with his expert file. 51. Any and all materials produced in the expert file of Roger Huckfeldt. 52. Deposition Transcript and Exhibits in this case: Roger Huckfeldt. 53. Demonstrative Exhibits needed to explain and/or illustrate his opinions. Syed Asad, M.D. 54. Records and materials provided to Dr. Asad for review and consideration and produced with his expert file. 55. Any and all materials produced in the expert file of Dr. Asad. 56. Deposition Transcript and Exhibits in this case: Dr. Asad. 57. Demonstrative Exhibits needed to explain and/or illustrate his opinions. Brian Pfeifer, Ph.D., P.E. 58. Records and materials provided to Dr. Pfeifer for review and consideration and produced with his expert file. 59. Any and all materials produced in the expert file of Brian Pfeifer. 60. Deposition Transcript and Exhibits in this case: Brian Pfeifer. 61. Demonstrative Exhibits needed to explain and/or illustrate his opinions. Adam Grill 62. Records and materials provided to Adam Grill for review and consideration and produced with his expert file. 63. Any and all materials produced in the expert file of Adam Grill. 64. Deposition Transcript and Exhibits in this case: Adam Grill. 65. Demonstrative Exhibits needed to explain and/or illustrate his opinions. R. Scott King, BSME, CFEI 66. Records and materials provided to Scott King for review and consideration and produced with his expert file. 67. Any and all materials produced in the expert file of Scott King. 68. Deposition Transcript and Exhibits in this case: Scott King. 69. Demonstrative Exhibits needed to explain and/or illustrate his opinions. Miscellaneous and Demonstrative 70. All deposition transcripts and exhibits for depositions not yet taken in this case, not otherwise objected to by Plaintiff. 71. All video deposition testimony taken in this case, not otherwise objected to by Plaintiff. Any information or documentation required to establish 72. curriculum vitae of Plaintiff’s experts, or to establish him or her as an expert. 73. Any exhibit necessary for rebuttal or impeachment purposes. 74. All prior testimony and financial bias documents of any disclosed defense expert. All references, cited authorities, texts, articles, books, videos, 75. studies, etc. referenced in the reports or deposition of any disclosed defense or plaintiff’s expert, timely produced and not otherwise objected to by Plaintiff. 76. Visual aids prepared by Plaintiff’s experts that will be used to explain and highlight their anticipated testimony. Any and all responses to discovery by any party or former 77. party to this lawsuit timely produced and not otherwise objected to by Plaintiff. Any and all responses to Requests for Admissions by any 78. party or former party to this lawsuit timely produced and not otherwise objected to by Plaintiff. Any and all exhibits and documents listed on any other party's 79. exhibit/document list or disclosure, timely produced and not otherwise objected to by Plaintiff. Any and all affidavits signed by any witness or party to this 80. matter, timely produced and not otherwise objected to by Plaintiff. All documents and items reviewed by plaintiff and defense 81. experts in this matter, timely produced and not otherwise objected to by Plaintiff. 82. All blowups, enlargements, etc. of any of the above exhibits. 83. Life mortality table(s). Medical illustrations, graphics, models, videos of Plaintiff’s surgeries and medical treatments showing procedure and/or 84. injuries, colorized PowerPoint slides and/or blowups demonstrating same and other demonstrative aids (currently undetermined). Further discovery is expected to reveal other exhibits or evidence which may be used by Plaintiff at trial. This fact may necessitate future amendments to Plaintiff’s Exhibit List. Plaintiff reserves the right to amend this list to include additional exhibits that may come to light, were mistakenly omitted, or which may be revealed through ongoing discovery in this matter. THE TRUCK ACCIDENT LAW FIRM /s/ Joseph V. Camerlengo, B.C.S. Joseph V. Camerlengo, B.C.S. Florida Bar No.: 008192 Jessica L. Lanifero, Esq. Florida Bar No. 021062 1200 Riverplace Blvd, Suite 902 Jacksonville, Florida 32207 Telephone: (904) 306-9220 Facsimile: (904) 306-9221 jvc@truckcrashlaw.com team@truckcrashlaw.com and ARONBERG, KOUSER, SNYDER & LINDERMANN, P.A. Daniel K. Snyder, admitted pro hac vice 430 Route 70 West Cherry Hill, New Jersey 08002 (856) 429-1700 dsnyder@akplaw.net Counsel for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 19th day of April, 2024, a true and correct copy of the foregoing has been filed with the Court via the Florida Courts E-Filing Portal which will send an electronic copy to all counsel of record. /s/ Joseph V. Camerlengo Attorney