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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 0:20-CV-61007-SINGHAL/VALLE

SOUTH BROWARD HOSPITAL DISTRICT d/b/a

MEMORIAL HEALTHCARE SYSTEM, on behalf of 

itself and all others similarly situated,

Plaintiff,

v.

ELAP SERVICES, LLC, a Pennsylvania limited 

liability company, and GROUP & PENSION 

ADMINISTRATORS, INC., a Texas corporation,

 Defendantss.

______________________________________________/

DECLARATION OF BENJAMIN J. WIDLANSKI

I, Benjamin J. Widlanski, declare as follows:

1. I am an attorney at Kozyak Tropin & Throckmorton LLP (“KTT”), counsel for 

Plaintiff and the putative class in the above-referenced matter. I am a member in good standing of 

The Florida Bar, I am over the age of eighteen, and I am competent to make this Declaration. 

2. I submit this Declaration in support of Plaintiff’s Daubert Motion to Exclude the 

Opinions of Defendants’ Rebuttal Expert, Bruce A. Strombom.

3. Attached under seal as Exhibit B is the March 24, 2023, Rebuttal Expert Report of 

Bruce A. Strombom, Ph.D.

4. Attached under seal as Exhibit C is the April 27, 2023, deposition transcript of 

Bruce A. Strombom.

5. Attached under seal as Exhibit D are pages from the September 15, 2022, 

deposition transcript of Woody Waters.

Case 0:20-cv-61007-AHS Document 171-1 Entered on FLSD Docket 06/12/2023 Page 1 of 3
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6. Attached under seal as Exhibit E is the Water Street due diligence Final read-out 

December 2015 Presentation produced in this litigation bearing the Bates numbers ELAP0136924

- ELAP0137029.

7. Attached under seal as Exhibit F are pages from the May 24, 2022, deposition 

transcript of Katie O'Leary.

8. Attached under seal as Exhibit G is a WR Meadows and GPA call on June 13, 

2018, produced by Defendants in this litigation bearing the Bates number ELAP0208513.

9. Attached under seal as Exhibit H is a WR Meadows and GPA call on June 13, 

2018, produced by Defendants in this litigation bearing the Bates number ELAP0138368.

10. Attached under seal as Exhibit I is a May 22, 2019, email produced by 

Defendants in this litigation bearing the Bates numbers ELAP0214438-ELAP0214452.

11. Attached under seal as Exhibit J is a July 22, 2020, email produced by Defendants 

in this litigation bearing the Bates numbers ELAP0181084-ELAP0181087.

12. Attached under seal as Exhibit K is a July 13, 2020, email produced by Defendants 

in this litigation bearing the Bates numbers ELAP0156566 – 156587.

13. Attached under seal as Exhibit L is a November 12, 2019, email produced by 

Defendants in this litigation bearing the Bates numbers ELAP0113802 - ELAP0113808.

14. Attached under seal as Exhibit M is a May 14, 2021, email produced by Defendants 

in this litigation bearing the Bates numbers ELAP0119214 - ELAP0119221.

15. Attached under seal as Exhibit N are pages from the August 2, 2022, deposition 

transcript of Jeffrey Bross.

16. Attached under seal as Exhibit O are pages from the December 14, 2022, 

deposition transcript of Deborah Doyle.

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17. Attached under seal as Exhibit P are pages from the November 16, 2022, 

deposition transcript of Patricia Holmes.

18. Attached under seal as Exhibit Q are pages from the August 1, 2022, deposition 

transcript of Emma Saintilus.

19. Attached under seal as Exhibit R are pages from the August 10, 2022, deposition 

transcript of Carmen Fajardo.

20. Attached under seal as Exhibit S are pages from the November 15, 2022, deposition 

transcript of Andrea Destefano.

21. Attached under seal as Exhibit T are pages from the August 12, 2022, deposition 

transcript of John Scozzaro.

22. Attached under seal as Exhibit U is a July 9, 2019, email and attachment produced 

by Defendants in this litigation bearing the Bates numbers ELAP0240110 - ELAP0240117. 

23. Attached under seal as Exhibit V is the Revised Expert Report of J. Mark 

Abernathy, CPA, CFF, CGMA, CVA.

Executed in Miami, Florida this 12

th day of June, 2023.

/s/ Benjamin J. Widlanski

Case 0:20-cv-61007-AHS Document 171-1 Entered on FLSD Docket 06/12/2023 Page 3 of 3