Opinion
2:20-CV-00062-JHC
06-01-2023
THERESE ROHLING PLATT, Plaintiff, v. HOLLAND AMERICA LINE, INC., a Washington corporation; HOLLAND AMERICA LINE - U.S.A., a Delaware corporation; HOLLAND AMERICA LINE, N.V. LLC., a Curacao corporation; and HAL ANTILLEN N.V., a Curacao corporation, Defendants.
PRETRIAL ORDER
HONORABLE JOHN H. CHUN JUDGE
JURISDICTION
This is an action by a passenger against the agents, owners, operator and charterers of a cruise ship. Subject matter jurisdiction is vested in the court pursuant to 28 U.S.C. § 1333 due to admiralty and maritime nature of the claim.
This Court has personal jurisdiction over Defendants based on their substantial, continuous, and systematic business contacts with the state of Washington.
CLAIMS AND DEFENSES
The Court has previously entered an order establishing as a matter of law the Defendants' liability for Plaintiff's electric shock. Dkt. # 18. Plaintiff maintains the claims in dispute are whether Plaintiff sustained an electrical shock and/or electrocution injury and whether that was the legal cause of Plaintiff's alleged injuries and damages and the extent of Plaintiff's injuries and damages, if any. Defendant maintains the claims in dispute, per the Court's previous order (Dkt. # 18, p. 2) are whether the electrical shock sustained by Plaintiff was the proximate cause of Plaintiff's alleged injuries and damages (if any) and the nature and extent of Plaintiff's injuries or damages (if any).
At trial, Plaintiff intends to prove that as a result of Defendants' negligence, Plaintiff has suffered serious injuries as a result of the electric shock occurring on Defendants' property, including, but not limited to, neurological injuries and damages resulting in bilateral frontal lobe seizure disorder, psychogenic nonepileptic seizures, peripheral nerve damage, neuropathy, severe pain in the upper and lower extremities, difficulty with concentration, short term memory loss, headaches, chronic pain, depression, anxiety, emotional distress and PTSD, cognitive impairment, pain and disability, and lost wages and limitations on her future earning capacity.
Plaintiff intends to prove that she has incurred significant past medical expenses and will incur future medical expenses related to her injuries. Plaintiff has experienced pain and suffering, both mental and physical, and disability, and with a reasonable certainty will experience the same in the future. Further, Plaintiff has suffered a reduction in Plaintiff's ability to enjoy life, both past and future, as she previously enjoyed due to her injuries and associated disabilities.
Defendants will pursue a failure to mitigate damages affirmative defense.
ADMITTED FACTS
The following facts are admitted by the parties:
1. That a Nestle Vitality Fruit Juice machine, Model No. JDF-4S-SB manufactured by the Bunn-O-Matic Corporation (“the Juice Machine”) located on-shore at Half Moon Cay in the Bahamas was ungrounded on or about April 11, 2019.
2. That Plaintiff sustained an electrical shock when she approached the Juice Machine barefoot and stepped on the wet ground in front of the machine (“the Incident”).
3. That Defendants were negligent in allowing an ungrounded Juice Machine to be used at the time of the Incident.
4. That, in light of the foregoing, Defendants admit liability for permitting an ungrounded Juice Machine to be used at the time of the Incident.
5. That Defendants also admit that Plaintiff is not comparatively at fault for sustaining the electrical shock from the Juice Machine.
ISSUES OF LAW
Plaintiff's Proposal:
Plaintiff does not believe there are any issues of law to be determined by the Court; however, there are issues of fact relating to the nature and extent of Plaintiff's injuries and associated damages.
Defendant's Proposal:
1. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from neurological injuries and damages resulting in bilateral frontal lobe seizure disorder proximately caused by the electric shock?
2. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from psychogenic nonepileptic seizures proximately caused by the electric shock?
3. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from peripheral nerve damage proximately caused by the electric shock?
4. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from neuropathy proximately caused by the shock?
5. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from severe pain in the upper and lower extremities proximately caused by the shock?
6. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from difficulty with concentration proximately caused by the shock?
7. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from short term memory loss proximately caused by the shock?
8. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from headaches proximately caused by the shock?
9. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from chronic pain proximately caused by the shock?
10. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from depression proximately caused by the shock?
11. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from anxiety proximately caused by the shock?
12. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from emotional distress proximately caused by the shock?
13. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from PTSD proximately caused by the shock?
14. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from cognitive impairment proximately caused by the shock.
15. Whether Plaintiff proves, by a preponderance of the evidence, that she suffers from pain and disability proximately caused by the shock?
16. Whether Plaintiff proves, by a preponderance of the evidence, that she suffered past lost wages proximately caused by the shock and the amount of those lost wages, if any?
17. Whether Plaintiff proves, by a preponderance of the evidence, loss of future earnings proximately caused by the shock and the amount of those lost future earnings, if any?
18. Whether Plaintiff proves, by a preponderance of the evidence, damages for past medical expenses proximately caused by the shock?
19. Whether Defendants proves, by a preponderance of the evidence, that Plaintiff failed to mitigate her damages?
EXPERT WITNESSES
The names and addresses of the expert witnesses to be used by each party at the trial and the issue upon which each will testify is:
(1) On behalf of Plaintiff:
a. Neil Pliskin, Ph.D., ABPP.CN
University of Illinois Department of Psychiatry
912 S Wood St.
Chicago, IL 60612
Will Testify
Dr. Pliskin is a board-certified Neuropsychologist and will offer expert opinions consistent with the expert disclosures previously made by Plaintiff.
b. Michael Morse, Ph.D.
4411 Point Loma Avenue
San Diego, CA 92107
Will Testify
Dr. Morse is an expert in Electrical Engineering and will offer expert opinions consistent with the expert disclosures previously made by Plaintiff and the Court's Order re: Defendants' Motions to Exclude/Motions in Limine (Dkt. # 91, pp. 5-6).
c. Rachel Steilberg, MS, CRC, CLCP
Vocational Consultant
Strategic Consulting Services, Inc.
1801 D Street Suite 4
Vancouver, WA 98663
Will Testify
Rachel Steilberg is a Certified Rehabilitation Counselor and will offer expert opinions consistent with the expert disclosures previously made by Plaintiff.
d. William G. Brandt, CPA, ABV, MBA, CFF
Forensic Economist
P.O. Box 10187
Bainbridge Island, WA 98110
Will Testify
William Brandt is a Forensic Economist and will offer expert opinions consistent with the expert disclosures previously made by Plaintiff.
e. Christopher Choi, MD
Concierge Wellness Center
4035 S El Capitan Way
Las Vegas, NV 89147
Will Testify (via video deposition)
Dr. Christopher Choi is Plaintiff's primary care physician and will testify concerning Plaintiff's injuries and symptoms caused by the electrocution, Plaintiff's medical treatment related to the electrocution, Plaintiff's permanent disabilities and physical restrictions caused by the electrocution, necessity of past treatment, the need for future treatment and corresponding cost of such treatment.
f. Venkat Veerappan, MD
Desert Neurology
9280 W. Sunset Road, Suite 236
Las Vegas, NV 89148
Will Testify (via video deposition)
Dr. Veerappan is a treating physician of Plaintiff. Dr. Veerappan will testify concerning Plaintiff's injuries and symptoms caused by the electrocution, Plaintiff's medical treatment related to the electrocution, Plaintiff's permanent disabilities and physical restrictions caused by the electrocution, necessity of past treatment, the need for future treatment and corresponding cost of such treatment.
g. Carissa DE Leeuw M.S., CCC-SLP
Speech Therapy Associates
501 S. Rancho Drive
Las Vegas, Nevada
Possible Witness Only
Carissa DE Leeuw is Plaintiff's treating speech-language pathologist. Ms. Leeuw would be expected to testify to the necessity of Plaintiff's speech therapy, the need for future therapies and the corresponding cost of such therapies.
h. Sharon Jung, Psy.D., ABPP-CN
Neurology Center of Nevada
653 N town Center Drive
Las Vegas, NV
Possible Witness Only
Dr. Jung is a treating physician of Plaintiff. Dr. Jung will testify concerning Plaintiff's psychological injuries and symptoms caused by the electrocution, Plaintiff's treatment related to the electrocution, necessity of past treatment, the need for future treatment and corresponding cost of such treatment.
i. Kenneth Houchin, M.D.
Elko Eye Center
875 14th St, Elko, NV 89801
Possible Witness Only
Dr. Houchin is Plaintiff's treating ophthalmologist. Dr. Houchin will testify concerning Plaintiff's vision and symptoms caused by the electrocution, Plaintiff's ophthalmology evaluations related to the electrocution, necessity of past evaluations, the need for future evaluations and corresponding cost.
j. Samir S. Bangalore, M.D.
Sunrise Hospital and Medical Center
3186 South Maryland Parkway
Las Vegas, NV 89109
Possible Witness Only
Dr. Bangalore is a board certified Neurologist and was Plaintiff's treating physician following her hospitalization at Sunrise Hospital. Dr. Bangalore will testify concerning their care and treatment of plaintiff as described in their medical records and the causal connection between the conditions they treated and diagnosed and plaintiff's electrocution. It is expected the testimony will describe the combination of epileptic seizures and nonepileptic seizures or psychogenic seizures and the causal connection to traumatic electrocution suffered by Mrs. Platt and resultant stress disorder. They will testify in a manner consistent with the medical records previously produced, care and treatment as well as recommendations to plaintiff for further evaluation of her psychogenic seizures.
k. Jeffrey Burton, D.O
United Critical Care
6040 S. Fort Apache Road, Suite 100
Las Vegas, NV 89148
Sunrise Hospital and Medical Center
3186 South Maryland Parkway
Las Vegas, NV 89109
Possible Witness Only
Dr. Burton is an internal medicine specialist and was Plaintiff's treating physician following her hospitalization at Sunrise Hospital. Dr. Burton will testify concerning their care and treatment of plaintiff as described in their medical records and the causal connection between the conditions they treated and diagnosed and plaintiff's electrocution. It is expected the testimony will describe the combination of epileptic seizures and nonepileptic seizures or psychogenic seizures and the causal connection to traumatic electrocution suffered by Mrs. Platt and resultant stress disorder. They will testify in a manner consistent with the medical records previously produced, care and treatment as well as recommendations to plaintiff for further evaluation of her psychogenic seizures.
(2) On behalf of Defendants:
a. Lawrence Murphy, MD.
4957 Lakemont Blvd, Suite C4, #23
Bellevue, WA 98006
Will testify.
Dr. Murphy is a neurologist. He will offer expert medical opinions within his area of expertise and consistent with expert disclosures previously made by Holland America
b. Kristoffer Rhoads, MD
41112th Ave, Suite 305
Seattle, WA 98122
Will testify.
Dr. Rhoads is a neuropsychologist and will offer expert medical opinions within his area of expertise and consistent with expert disclosures previously made by Holland America.
c. Bill Partin or Casey Lesoing
Mueller & Partin
4001108th Ave NE
Bellevue, WA 98004
Will testify.
Messrs. Partin and Lesoing are forensic accountants and economists. One will be called to testify at trial and will offer opinions consistent with Holland America's expert disclosures concerning Plaintiff's claimed economic damages.
OTHER WITNESSES
The names and addresses of witnesses, other than experts, to be used by each party at the time of trial and the general nature of the testimony of each are:
(1) On behalf of Plaintiff:
a. Therese Rohling Platt
11720 Glowing Sunset Lane
Las Vegas, Nevada 89135
Will Testify
Plaintiff will testify to the facts and circumstances of the incident described in the complaint, negligence of the defendants, and her injuries and damages related to those injuries.
b. William Stephan Platt
11720 Glowing Sunset Lane
Las Vegas, Nevada 89135
Will Testify
Mr. Platt will testify to the facts and circumstances of the incident described in the Complaint, negligence of the defendants, Plaintiff's physical condition prior to her injuries, her condition subsequent to her injuries, effects of the injuries on Plaintiff as observed by him and damages related to the incident.
c. Stephen Laverton
Employee of Holland America
Via Deposition
Security Officer for Holland America. Mr. Laverton will testify to his knowledge of the facts and circumstances of the incident described in the Complaint, his investigation of the beverage dispenser and surrounding area and statement taken from Plaintiff.
d. Anthony Black
Little San Salvador, Bahamas
Employee of Holland America
Via Deposition
Island Manager for Half Moon Cay, Bahamas. Mr. Black will testify regarding the incident described in the complaint and any other matters pertinent to this action.
e. Kathleen Eisert
910 Sunrise Drive
Wapakoneta, Ohio 45895
Via Deposition
Eyewitness to the incident. Ms. Eisert will testify to her observations of the incident described in the Complaint.
f. Sherry Watford
2 Meadow Crossing Court
Greensboro, North Carolina
Via Deposition
Eyewitness to the incident. Ms. Watford will testify to her observations of the incident described in the Complaint.
g. Records Custodian - Nevada State College
To lay foundation and authenticate records.
Possible Witness Only
h. Records Custodian/Vincent Lawsin - Swedish Hospital
To lay foundation and authenticate records.
Possible Witness Only
i. Records Custodian - Speech Therapy Associates
To lay foundation and authenticate records.
Possible Witness Only
j. Author of Videos/Records Custodian - Summerlin Hospital
To lay foundation and authenticate records and videos (See Exhibits 4664).
Possible Witness Only
(2) On behalf of Defendants:
a. James P. Colwell
Holland America Line
450 3rd Ave W
Seattle, WA 98119
Possible witness only.
Mr. Colwell is the P&I Litigation and Claims Manager for Holland America Group. He may have information regarding Plaintiff's claim, Holland America procedures and records, and any other matters pertinent to this action.
b. Jeroen De Winter
Holland America Line
450 3rd Ave W
Seattle, WA 98119
Possible witness only.
Mr. De Winter was the Staff Captain aboard the ZUIDERDAM. He may be called to testify regarding the incident, investigation, Holland America documents, vessel procedures and actions, interactions with Mr. and Mrs. Platt, and any other matters pertinent to this action.
c. Steve Laverton
Holland America Line
450 3rd Ave W
Seattle, WA 98119
Will testify.
Mr. Laverton was a Security Officer aboard the ZUIDERDAM. He interviewed Ms. Platt and has information consistent with that provided in his Investigation Report and will be called testify as to his investigation, observations, and any other matters pertinent to this action.
d. Aileen Ley Siscar, MD
Holland America Line
450 3rd Ave W
Seattle, WA 98119
Possible witness only.
Dr. Siscar was a ship's physician aboard the ZUIDERDAM and may be called to testify regarding Plaintiff's condition and his treatment of Plaintiff.
e. Anthony Black
Little San Salvador
Bahamas
Possible witness only.
Mr. Black was the Island Manager for Half Moon Cay, Bahamas and may be called to testify regarding alleged incident and any other matters pertinent to this action.
Defendant objects to Mr. Lawsin being called as a witness. Defendant asserts he was not timely disclosed.
EXHIBITS
Plaintiff's Exhibits
Ex. #
Description
Authenticity
Admissibility
Objection
Admitted
1.
Photo - Half Moon Cay Sign - (Platt 357)
Stipulated
Stipulated
2.
Photo - Plaintiff onboard - (Platt 379)
Stipulated
Stipulated
3.
Photo - Plaintiff on land - (Platt 363)
Stipulated
Stipulated
4.
Photo - Plaintiff with Husband by ship -(Platt 397)
Stipulated
Stipulated
5.
Photo - Plaintiff with First Responders -(Platt 189)
Stipulated
Stipulated
6.
Defendant Investigation Photos -(HAL 000005-000026)
Stipulated
Stipulate to: HAL005 HAL006 HAL007 HAL014 HAL015 HAL016 Disputed: HAL008 HAL009 HAL010 HAL011
HAL012 HAL013 HAL017 HAL018 HAL109 HAL020 HAL021 HAL022 HAL023 HAL024 HAL025 HAL026
7.
Defendant Investigation Report -(HAL 000027-000028)
Stipulated
Stipulated
8.
Defendant Initial Findings - (HAL 000029-222230)
Stipulated
Disputed
FRE 401/402; 403
9.
Crewmember Statement - Najmudin - (HAL 000031000032)
Stipulated
Stipulated
10.
Crewmember Statement - De La Rosa - (HAL 000033000034)
Stipulated
Stipulated
11.
Plaintiff Guest Statement and Injury Report - (HAL 000035-000037)
Stipulated
Stipulated
12.
Boarding Pass/ Boarding Tickets -(Platt 1-3)
Stipulated
Stipulated
13.
Awards & School Transcript - (Platt 442447)
Disputed
Disputed
14.
Plaintiff's Resume -(Platt 857)
Stipulated
Disputed
15.
Swedish Hospital Job Offer to Plaintiff -2017 - (Platt 858-860)
Disputed
Disputed
16.
Plaintiff's 2014 W2 -(Platt 847)
Stipulated
Stipulated
17.
Plaintiff's 2015 Tax Return - (Platt 848 -856)
Stipulated
Stipulated
18.
Desert Neurology -Medical Records
Stipulated
Disputed
Foundation, FRE 403
19.
Concierge Wellness Center - Medical Records
Stipulated
Disputed
Foundation, FRE 403
20.
Pueblo Medical Imaging - Medical Records
Stipulated
Disputed
21.
SeaCare - Medical Records
Stipulated
Stipulated
22.
St. Elizabeth Hospital - Medical Records
Stipulated
Disputed
Foundation; FRE 403,
23.
Steinberg Diagnostic Medical Imaging -Medical Records
Stipulated
Disputed
Foundation; FRE 403
24.
Neurology Center of Nevada - Medical Records
Stipulated
Disputed
Foundation; FRE 403
25.
Speech Therapy Associates - Medical Records
Disputed
Disputed
26.
Advanced Cardiovascular Specialists - Medical Records
Stipulated
Disputed
Foundation; FRE 403
27.
Sage Acupuncture Clinic - Medical Records
Stipulated
Disputed
28.
Elko Eye Center -Medical Records
Stipulated
Disputed
Foundation; FRE 403
29.
Summerlin Hospital -Medical Records
Stipulated
Disputed
Foundation; FRE 403
30.
Sunrise Hospital -Medical Records
Stipulated
Stipulated
31.
Integrated Psychological Solutions - Medical Records
Stipulated
Disputed
Excluded by court (Dkt. # 85), ER 403
32.
Desert Neurology -Itemized Billing
Stipulated
Disputed
Foundation, FRE 403
33.
Concierge Wellness Center - Itemized Billing
Stipulated
Stipulated
34.
Pueblo Imaging -Itemized Billing
Stipulated
Disputed
Foundation, FRE 403
35.
SeCare/St. Elizabeth Hospital - Itemized Billing
Stipulated
Disputed
Foundation, FRE 403
36.
Steinberg Diagnostic -- Itemized Billing
Stipulated
Disputed
Foundation, FRE 403
37.
Neurology Center of Nevada - Itemized Billing
Stipulated
Disputed
Foundation, FRE 403
38.
Speech Therapy Associates - Itemized Billing
Stipulated
Disputed
Foundation, FRE 403
39.
Advanced Cardiovascular Specialists - Itemized Billing
Stipulated
Disputed
Foundation, FRE 403
40.
Sage Acupuncture -Itemized Billing
Stipulated
Disputed
Foundation, FRE 403
41.
Elko Eye Center -Itemized Billing
Stipulated
Disputed
Foundation, FRE 403
42.
Summerlin Hospital -Itemized Billing
Stipulated
Disputed
Foundation, FRE 403
43.
Sunrise Hospital -Itemized Billing
Stipulated
Disputed
Foundation, FRE 403
44.
Integrated Psychological Solutions - Itemized Billing
Stipulated
Disputed
Excluded by court (Dkt. # 85); ER 402, 403.
45.
Itemization of Incurred Expenses
Disputed
Disputed
46.
Video 1 - IMG 4836 -EEG Monitor 11/2/22 at Sunrise Hospital
Disputed
Disputed
47.
Video 2 - IMG 4837 -EEG Monitor 11/2/22 at Sunrise Hospital
Disputed
Disputed
48.
Video 3 - IMG 4838 -EEG Monitor 11/2/22 at Sunrise Hospital
Disputed
Disputed
49.
Video 4 - IMG 4841-EEG Monitor 11/4/2022 at Sunrise Hospital
Disputed
Disputed
50.
Video 5 - IMG 4842 -EEG Monitor 11/4/2022 at Sunrise Hospital
Disputed
Disputed
51.
Video 6 - IMG 4843 -EEG Monitor 11/4/2022 at Sunrise Hospital
Disputed
Disputed
52.
Video 7 - IMG 4844 -EEG Monitor 11/4/2022 at Sunrise Hospital
Disputed
Disputed
53.
Video 8 - IMG 5582 -Seizure at Home
Disputed
Disputed
54.
Video 9 - IMG 5583 -Seizure at Home
Disputed
Disputed
55.
Video 10 - IMG 5603 - Seizure at Summerlin Hospital
Disputed
Disputed
56.
Video 11 - IMG 5604 - Seizure at Summerlin Hospital
Disputed
Disputed
57.
Video 12 - IMG 5605 - Seizure at Summerlin Hospital
Disputed
Disputed
58.
Video 13 - IMG 5606 - Seizure at Summerlin Hospital
Disputed
Disputed
59.
Video 14 - IMG 5607 - Seizure at Summerlin Hospital
Disputed
Disputed
60.
Video 15 - IMG 5608 - Seizure at Summerlin Hospital
Disputed
Disputed
61.
Video 16 - IMG 5615 - Summerlin Hospital
Disputed
Disputed
62.
Video 17 - IMG 5616 - Summerlin Hospital
Disputed
Disputed
63.
Video 18 - IMG 5617 - Summerlin Hospital
Disputed
Disputed
64.
Video 19 - IMG 5618 - Summerlin Hospital
Disputed
Disputed
65.
Article 1 - The Truth about Psychogenic Nonepileptic Seizures
Disputed
Disputed
66.
Article 2 -Psychogenic Nonepileptic Seizures
Disputed
Disputed
67.
Article 3 - Driving a motor vehicle and psychogenic nonepileptic seizures
Disputed
Disputed
68.
Article 4 - Long-term sequelae of electrical injury
Disputed
Disputed
69.
Article 5 -Neuropsychologi cal changes following electrical injury
Disputed
Disputed
70.
Article 6 - Psychiatric morbidity following electrical injury and its effects on cognitive functioning
Disputed
Disputed
71.
Article 7 - Long-term consequences of electrical injury: neuropsychologi cal predictors and adjustment
Disputed
Disputed
72.
Article 8 - Mood and Cognition after Electrical Injury
Disputed
Disputed
73.
Article 9 - Alteration in Functional Brain Systems after Electrical Injury
Disputed
Disputed
74.
Article 10 -Neurological symptoms and disorders following electrical injury
Disputed
Disputed
75.
Article 11 -Neurological and neurourological complications of electrical injuries
Disputed
Disputed
76.
Article 12 - Why Won't People Talk about Psychogenic Nonepiliptic Seizures
Disputed
Disputed
77.
Article 13 -Simultaneous Occurrence of
Disputed
Disputed
Nonepileptic ... El-Naggar 2017
78.
Article 14 - Dual Diagnosis of Epilepsy ... Mansur A. Kutlubaev
Disputed
Disputed
79.
Article 15 - Lezak 1995 - Neuropsychologi cal Assessment
Disputed
Disputed
80.
Article 16 -Assessment of differential neurocognitive, et al
Disputed
Disputed
81.
Article 17 -Psychometric implications of fails
Disputed
Disputed
82.
Article 18 - Electrical Injuries: Neurologic Complications
Disputed
Disputed
83.
Dr. Michael Morse -Curriculum Vitae, Reports, Attachments, Figures.
Stipulated
Disputed
84.
Dr. Neil Pliskin -Curriculum Vitae, Reports, Attachments, Figures.
Stipulated
Disputed
85.
Dr. William Brandt -Curriculum Vitae, Reports, Attachments, Figures.
Stipulated
Disputed
86.
Rachel Steilberg, MS -Curriculum Vitae, Reports, Attachments, Figures.
Stipulated
Disputed
87.
Dr. Samir Bangalor -Curriculum Vitae
Disputed
Disputed
88.
Dr. Venkat Veerappan - Curriculum Vitae
Disputed
Disputed
89.
Plaintiff's messaging -Platt 197-206
Stipulated
Stipulated
90.
Plaintiff's journal -Platt 234-315
Stipulated
Stipulated
91.
Steve Platt correspondence to Dr. Choi - Platt 230-233
Stipulated
Stipulated
92.
Steve Platt correspondence to Don Westra - Platt 327-329
Stipulated
Stipulated
93.
Plaintiff's photographs from her cruise - Platt 341-441
Stipulated
Stipulated
94.
12/2/2011 Summerlin Hospital record - HAL 452-458
Stipulated
Stipulated
95.
9/2/2014 Summerlin Hospital record - HAL 488-509
Stipulated
Stipulated
96.
Dr. Adams record 6/24/2015 - Platt 22242228
Stipulated
Stipulated
97.
Dr. Adams record 9/28/2015 - Platt 727731
Stipulated
Stipulated
Defendant's Exhibits
Ex. #
Description
Authenticity
Admissibility
Objection
Admitted
500.
Photo of Gazebo -HAL 38
Stipulated
Stipulated
501.
“From the Captain” -HAL 179-194
Stipulated
Stipulated
502.
Partin report, CV, and attachments.
Disputed
Disputed
Foundation/ FRE 802
503.
Dr. Murphy CV, reports, and supplements.
Disputed
Disputed
Foundation/ FRE 802
504.
Dr. Rhoads CV, reports, and supplements.
Disputed
Disputed
Foundation/FRE 802
ACTION BY THE COURT
(a) This case is scheduled for trial on June 12, 2023.
(b) Trial briefs shall be submitted to the court on or before June 5, 2023.