Case 0:20-cv-61608-RAR Document 57 Entered on FLSD Docket 06/13/2021 Page 1 of 5
 CASE NO.: 20-cv-61608-RAR

2 

150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 

TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690

incident, and lack of notice of the alleged 

dangerous condition and insufficient time 

to correct same. 

3. Joseph Richards, PA-C

Broward Health North 

201 E. Sample Road 

Deerfield Beach, FL

Mr. Richards is believed to possess 

knowledge regarding Plaintiff’s alleged 

injuries and the medical treatment provided 

to her on October 7, 2019.

√

4. Meena Hierholzer, D.O.

Broward Health North 

201 E. Sample Road 

Deerfield Beach, FL

Dr. Hierholzer is believed to possess 

knowledge regarding Plaintiff’s alleged 

injuries and the medical treatment provided 

to her on October 7, 2019. 

√

5. Craig D. Steiner, M.D.

600 S. Pine Island Rd. 

Ste. 300 

Plantation, FL33324 

Dr. Steinger is expected to testify, from an

orthopedic standpoint, regarding the nature, 

cause and extent of the alleged injuries 

Plaintiff claims she sustained as a result of 

the incident at Walmart. He will testify 

about the reasonableness and necessity of 

the medical treatment received by the 

Plaintiff and whether Plaintiff needs any 

future medical care or treatment as a result 

of the incident alleged. Dr. Steiner will also 

discuss the relationship of Plaintiff’s preexisting conditions to the injuries she 

allegedly sustained as a result of the subject 

incident. Dr. Steiner will offer opinions on 

medical causation and will rebut the 

opinions of Plaintiff’s treating physicians, 

if any. Dr. Steiner will also testify 

concerning the reasonableness of Plaintiff’s 

medical bills.

√

Case 0:20-cv-61608-RAR Document 57 Entered on FLSD Docket 06/13/2021 Page 2 of 5
 CASE NO.: 20-cv-61608-RAR

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150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 

TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690

6. Robert L. Kagan, M.D.

Sunshine Readers, Inc. 

3032 E. Commercial Boulevard 

Suite #54 

Ft. Lauderdale, Florida 33308 

Dr. Kagan is expected to testify about 

observations 

and opinions within the field of radiology 

and human physiology after reviewing 

Plaintiff’s diagnostic films and medical 

records. Dr. Kagan is expected to testify

concerning the nature, extent, and validity, 

if any, of Plaintiff’s alleged injuries. Dr. 

Kagan will discuss his opinions on 

Plaintiff’s pre and post injury diagnostic 

films including whether Plaintiff’s 

diagnostic films evidence acute, chronic 

and/or degenerative conditions. Dr. Kagan 

will also rebut the testimony of Plaintiff’s 

experts, if any, and treating physicians with 

respect to the conditions noted on 

Plaintiff’s diagnostic films.

√

7. Marilyn Pacheco, CPC

Elevate Services, Inc.

1711 W. Greentree Dr.

Suite 108 

Tempe, AZ 85284 

Ms. Pacheco is expected to testify 

concerning the appropriateness of the 

coding for the medical services provided to 

Plaintiff and the reasonableness of 

Plaintiff’s medical bills. She is expected to 

testify concerning the appropriateness of 

coding for the services provided and the 

reasonableness of Plaintiff’s medical

bills against geographically adjusted usual, 

customary and reasonable rates. Ms. 

Pacheco will be rebutting all the allegations 

raised in Plaintiff’s Complaint relating to 

her field of expertise. Ms. Pacheco will be 

providing rebuttal opinions to Plaintiff’s 

experts, if any, regarding the 

reasonableness of Plaintiff’s medical bills.

√

 

Case 0:20-cv-61608-RAR Document 57 Entered on FLSD Docket 06/13/2021 Page 3 of 5
 CASE NO.: 20-cv-61608-RAR

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150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 

TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690

Respectfully submitted, 

/s/ Suzette L. Russomanno 

 Jerry D. Hamilton

Florida Bar No. 970700

 jhamilton@hamiltonmillerlaw.com

Suzette L. Russomanno, Esq. 

 Florida Bar No.: 751081 

srussomanno@hamiltonmillerlaw.com 

HAMILTON, MILLER & BIRTHISEL, LLP

Attorneys for Defendant Wal-Mart Stores East, LP

150 Southeast Second Avenue, Suite 1200 

 Miami, Florida 33131-2332 

 Telephone: (305) 379-3686 

 Facsimile: (305) 379-3690 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on June 13, 2021, I electronically filed the foregoing document 

with the Clerk of the Court using CM/ECF. I also certify that the foregoing is being served this day 

on all counsel of record or pro se parties identified on the following Service List in the manner 

specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some 

other authorized manner for those counsel or parties who are not authorized to receive electronically 

notices of Electronic Filing.

/s/ Suzette L. Russomanno

 Suzette L. Russomanno

Case 0:20-cv-61608-RAR Document 57 Entered on FLSD Docket 06/13/2021 Page 4 of 5
 CASE NO.: 20-cv-61608-RAR

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150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 

TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690

SERVICE LIST

Carlos A. Jordi, Esq. 

Rubenstein Law, P.A. 

201 N. University Drive, Suite 700 

Plantation, Florida 33324 

Telephone: (305) 661-6000 

Facsimile: (305) 670-7555 

cjordi@rubensteinlaw.com 

crios@rubensteinlaw.com 

eservice@rubensteinlaw.com 

Attorneys for Plaintiff Tomasa Fortaneli Ponce

Case 0:20-cv-61608-RAR Document 57 Entered on FLSD Docket 06/13/2021 Page 5 of 5