IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA, NORTHERN DIVISION

WILLIAM D. BOWDEN, )

)

Plaintiff, )

)

v. ) Civil Action No.: 2:06-cv-665

)

MISSION PETROLEUM CARRIERS, )

ANTONIO MARTINEZ NAVARRO )

)

Defendants. )

NOTICE OF FILING DEFENDANTS’ EXPERT DISCLOSURES

Defendants Mission Petroleum Carriers and Antonio Martinez Navarro hereby

give notice of filing Defendants’ Expert Disclosures. 

Respectfully submitted on the 28th day of February, 2006.

/s/ Caroline T. Pryor 

VINCENT A. NOLETTO, JR. 

(NOLEV3868)

CAROLINE T.

PRYOR(PRYOC2802)

Attorney for Defendants

CARR ALLISON

6251 Monroe Street, Suite 200

Daphne, Alabama 36526

(251)626-9340 telephone

(251)626-8928 facsimile

ctp@carrallison.com

CERTIFICATE OF SERVICE

I hereby certify that I have on this 28th of February, 2006, served a copy of the foregoing

pleading upon all counsel of record via the Court’s electronic filing system.

James Bodin, Esq.

McPhillips, Shinbaum & Gill, LLP

P.O. Box 64

Montgomery, AL 36101-0064

/s/ Caroline T. Pryor 

CAROLINE T. PRYOR

Case 2:06-cv-00665-WHA-WC Document 20 Filed 02/28/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA, NORTHERN DIVISION

WILLIAM D. BOWDEN, )

)

Plaintiff, )

)

v. ) Civil Action No.: 2:06-cv-665

)

MISSION PETROLEUM CARRIERS, )

ANTONIO MARTINEZ NAVARRO )

)

Defendants. )

DEFENDANTS’ EXPERT DISCLOSURES

COME NOW the Defendants, Mission Petroleum Carriers and Antonio Navarro, and

pursuant to the Federal Rules of Civil Procedure and by way of supplement to Plaintiff’s

discovery requests, designate the following experts:

1. Doug Miller, vocational disability consultant, 813 Downtowner Blvd., Suite C,

Mobile, Alabama; 1-251-432-6335. A copy of Mr. Miller’s resume is enclosed. Mr. Miller is a

vocational disability specialist and is expected to testify concerning Mr. Bowden’s vocational

status, including jobs available to him within restrictions assigned by his treating physicians. In

addition, the Defendants have requested Plaintiff present to Mr. Miller for a vocational

assessment. It is expected that Mr. Miller will render opinions regarding the vocational

assessment that he conducts in addition to the aforementioned matters. Mr. Miller has not yet

generated a report. However, following a vocational assessment, as conducted by Mr. Miller, a

report will be generated and provided. 

2. The Defendants reserve the right to call Plaintiff’s treating providers including:

a. Patrick Ryan, M.D.;

b. Mike Easterling, M.D., Montgomery Neurosurgical Associates;

c. Roger Kemp, M.D., Central Alabama Pain Management Center, P.C.,

Case 2:06-cv-00665-WHA-WC Document 20 Filed 02/28/2007 Page 2 of 3
1722 Pine Street, Montgomery, Alabama 36106;

d. Caudill Miller, M.D., 1722 Pine Street, Montgomery, Alabama 36106;

e. Patrick Couch, M.D., Physicians Pain Specialist, Mobile, Alabama 36607;

3. Any and all physicians who have treated Plaintiff for injuries at any time but have

not previously been disclosed and are later discovered during the course of discovery.

4. Defendants reserve the right to supplement their expert disclosures in

accordance with the Federal Rules of Civil Procedure and the scheduling order entered in this

case. 

Respectfully submitted,

__/s/ Caroline T. Pryor___________

VINCENT A. NOLETTO, JR. (NOL008)

CAROLINE T. PRYOR (PRY005)

Attorneys for Defendant

OF COUNSEL:

CARR ALLISON

P.O. Box 1126

Daphne, AL 36526

251-626-9340

ctp@carrallison.com

CERTIFICATE OF SERVICE

I do hereby certify that I have on this 28th day of February, 2007, I electronically filed the

foregoing with the Clerk of the Court using the CM/ECF system which will send notification of

such filing to the following and that I hereby certify that I have mailed by placing a copy of same

in the United States Mail, first-class postage prepaid and properly addressed those non

CM/ECF participants:

James Bodin

McPhillips, Shinbaum & Gill, L.L.P.

Post Office Box 64

Montgomery, Alabama 36101-0064

/s/ Caroline T. Pryor_______________

OF COUNSEL

Case 2:06-cv-00665-WHA-WC Document 20 Filed 02/28/2007 Page 3 of 3