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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS 

MIDLAND-ODESSA DIVISION

TERRY MEEKS § 

§

 Plaintiff, § 

§ 

v. § 

§ 

Civil Action No. 7:20-cv-00113

IBN UTHMAN KEARSE AND 

CAMERON LOGISTICS, LLC.

§ 

§

 Defendants. § 

PLAINTIFF’S EXPERT DESIGNATION

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES Plaintiff, TERRY MEEKS, and files this his Designation of Expert 

Witnesses pursuant to the Scheduling Order in effect in this matter, and as previously identified in 

Plaintiff’s Initial Disclosure, and as supplementation of any previous response to a discovery 

request pursuant to the Federal Rules of Civil Procedure and local rules thereto.

Non Retained Experts

Although not retained as testifying experts by Plaintiff herein, the following individuals 

possess the necessary skill, experience, training, and education to render expert opinions pursuant 

to Rule 702 of the Federal Rules of Evidence, and are hereby designated as expert witnesses by 

Plaintiff herein:

Odessa Police Department, including but not limited to Officer Alexis Ortiz, Badge 

No. 0216, and representatives, agents, and custodians of records.

205 N. Grant Avenue

Odessa, Texas 79761

T: 432-333-3641

Will testify concerning their investigation of the accident and any opinions they 

concluded from that investigation. They will also testify factually of their investigatory 

findings and utilize any and all photographs or drawings as part of their official file 

necessary to support their findings. Their testimony will include not only any facts they 

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observed but any opinions based upon their expertise, training, and experience with 

respect to causation and fault of the collision.

NHH Services & Medallion Transport Holding, Inc, including but not limited to 

representatives, agents, and the custodian of records

307 Oates Road, Suite H

Mooresville, NC 28117

Will testify with regard to the nature of Mr. Meek’s self-employment, including but not 

limited to the legal nature of the employment, the details of employment and the financial 

compensation of the employment.

St. Lucie Appraisal Company, including but not limited to Franklin Colletta, 

representatives, agents, and the custodian of records

T: 772-359-4300

contact@stlucieappraisal.net

Will testify with regard to the appraisal and determination of diminished value of Plaintiff’s 

trailer after the collision.

Midland Emergency Management

P.O. Box 734896

Chicago, IL 60673

T: 800-225-0953

Will testify with regard to Mr. Meek’s imaging for injuries sustained as a result of the 

motor vehicle collision made the basis of this lawsuit. Testimony will be offered 

concerning the imaging, examination, care and treatment for complaints of back and 

shoulder pain sustained in the motor vehicle collision made the basis of this suit. Will also 

testify that the services rendered for the care and treatment of Plaintiff were reasonable and 

necessary and that the charges for those services rendered in that county were reasonable, 

usual, and customary.

Midland Memorial Hospital, Including but not limited to, representatives, agent and 

the Custodian of Records

400 Rosalind Redfern Grover Parkway

Midland, Texas 79701

T: 432-221-1111

Will testify with regard to Mr. Meek’s imaging for injuries sustained as a result of the 

motor vehicle collision made the basis of this lawsuit. Testimony will be offered 

concerning the imaging, examination, care and treatment for complaints of back and 

shoulder pain sustained in the motor vehicle collision made the basis of this suit. Will also 

testify that the services rendered for the care and treatment of Plaintiff were reasonable and 

necessary and that the charges for those services rendered in that county were reasonable, 

usual, and customary.

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Southwest Medical Imaging, Inc., including but not limited to representatives, agents 

and the Custodian of Records

PO Box 1512

Lowell, AR 72745

T: 888-929-1178

Will testify with regard to Mr. Meek’s imaging for injuries sustained as a result of the 

motor vehicle collision made the basis of this lawsuit. Testimony will be offered 

concerning the imaging, examination, care and treatment for complaints of back and 

shoulder pain sustained in the motor vehicle collision made the basis of this suit. Will also 

testify that the services rendered for the care and treatment of Plaintiff were reasonable and 

necessary and that the charges for those services rendered in that county were reasonable, 

usual, and customary.

Back Pain Institute, including but not limited to representatives, agents and the 

Custodian of Records

1030 N. Grandview

Odessa, Texas 79761

T: 432-332-3388

F: 432-332-3390

Will testify with regard to Mr. Meek’s pain management, care, and treatment for injuries 

sustained as a result of the motor vehicle collision made the basis of this lawsuit. 

Testimony will be offered concerning the examination, care, and treatment for 

complaints of back and shoulder following the motor vehicle collision made the basis 

of this suit. Will also testify that the services rendered for the care and treatment of 

Plaintiff were reasonable and necessary and that the charges for those services 

rendered in that county were reasonable, usual, and customary.

Dr. Elliot I. Clemence, including but not limited to representatives, agents and the 

Custodian of Records

7500 Barlite Blvd. Suite 309

San Antonio, Texas 78224

T: 210-924-9000

F: 210-924-7300

Will testify with regard to Mr. Meek’s pain management, care, and treatment for injuries 

sustained as a result of the motor vehicle collision made the basis of this lawsuit. 

Testimony will be offered concerning the examination, care, and treatment for 

complaints of back and shoulder pain following the motor vehicle collision made the 

basis of this suit. Will also testify that the services rendered for the care and treatment 

of Plaintiff were reasonable and necessary and that the charges for those services 

rendered in that county were reasonable, usual, and customary. He will further testify as 

to the meaning and impact the injury on Plaintiff’s health now and in the future. He will 

further testify as to the necessity and the reasonable and necessary costs associated with all 

future medical care and treatment for the injuries sustained in the collision made the basis 

of this lawsuit. He may also refer to and testify based upon other medical providers’ 

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records. The Doctor will testify that, to a reasonable degree of medical certainty, the 

collision made the basis of this lawsuit caused the injuries of which Plaintiff complains. 

You are referred to this medical provider’s records for his care and treatment of the 

Plaintiff.

Dr. Frank Kuwamura, III, including but not limited to representatives, agents and 

the Custodian of Records

525 Oak Centre, Suite 100

San Antonio, Texas 78258

T: 210-504-3650

Will testify with regard to Mr. Meek’s pain management, care, and treatment for injuries 

sustained as a result of the motor vehicle collision made the basis of this lawsuit. 

Testimony will be offered concerning the examination, care, and treatment for complaints 

of back and shoulder pain following the motor vehicle collision made the basis of this suit. 

Will also testify that the services rendered for the care and treatment of Plaintiff were 

reasonable and necessary and that the charges for those services rendered in that county 

were reasonable, usual, and customary. He will further testify as to the meaning and impact 

of injury on the Plaintiff’s health now and in the future. He will further testify as to the 

necessity and the reasonable and necessary costs associated with all future medical 

care and treatment for the injuries sustained in the collision made the basis of this 

lawsuit. He may also refer to and testify based upon other medical providers ’records. 

The Doctor will testify that, to a reasonable degree of medical certainty, the

collision made the basis of this lawsuit caused the injuries of which Plaintiff 

complains. You are referred to this medical provider’s records for his care and treatment 

of the Plaintiff.

The following procedure has been recommended by Dr. Kuwamura as set out in his 

medical records: The recommended surgical intervention for Mr. Meeks is an anterior 

cervical discectomy with artificial disc replacement at C5/6. The estimated cost for this 

surgery would be $228,000.

Golder CAT Scan& MRI, including but not limited to representatives, agents and the 

Custodian of Records

613 Golder Avenue

Odessa, Texas 79761

T: 432-333-4906

F: 432-580-9898

Will testify with regard to Mr. Meek’s imaging for injuries sustained as a result of the 

motor vehicle collision made the basis of this lawsuit. Testimony will be offered 

concerning the imaging, examination, care and treatment for complaints of back and 

shoulder pain sustained in the motor vehicle collision made the basis of this suit. Will also 

testify that the services rendered for the care and treatment of Plaintiff were reasonable and 

necessary and that the charges for those services rendered in that county were reasonable, 

usual, and customary.

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Optimus Physical Therapy

4311 Andrews Hwy

Midland, TX 79703

T: 432-520-5600

Will testify with regard to Mr. Meek’s chiropractic care and treatment for injuries sustained 

as a result of the motor vehicle collision made the basis of this lawsuit. Testimony will be 

offered concerning the examination, care, and treatment for complaints of back and right 

wrist pain following the motor vehicle collision made the basis of this suit. Will also testify 

that the services rendered for the care and treatment of Plaintiff were reasonable and 

necessary and that the charges for those services rendered in that county were reasonable, 

usual, and customary.

Texas Tech Physicians of the Permian Basin

301 N. Avenue N

Midland, TX 79701

T: 432-620-5800

Will testify with regard to Mr. Meek’s care and treatment for injuries sustained by as a 

result of the motor vehicle collision made the basis of this lawsuit. Testimony will be 

offered concerning the examination, imaging, and medical treatment to Plaintiff for injuries 

sustained, care and treatment for complaints of the right wrist following the motor vehicle 

collision made the basis of this suit. Will also testify that the services rendered for the care 

and treatment of Plaintiff were reasonable and necessary and that the charges for those 

services rendered in that county were reasonable, usual and customary. 

Plaintiff further designates any witness who has been or is subsequently deposed, who by 

their education, training, or experience qualifies to offer opinion testimony under the Federal Rules 

of Evidence.

Retained Experts

Plaintiff has not formally retained any expert witnesses at this time.

Non-Exclusive Reservations

Plaintiff reserves the right to cross-designate and cross-examine expert witnesses identified 

or designated by any other party or any employee or representative of any other party to elicit 

expert opinions subject to any objections Plaintiff may make concerning the designation of those 

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experts.

Plaintiff reserves the right to supplement or amend this designation within the limitations 

imposed by the Court, within any alterations or scheduling by subsequent Court Order or 

agreement of the parties, and/or pursuant to the Federal Rules of Civil Procedure and local rules 

thereto, and the Federal Rules of Evidence.

Plaintiff reserves the right to identify experts in rebuttal to those experts identified by the 

Defendant.

Plaintiff reserves the right to call undesignated, rebuttal expert witnesses whose testimony 

cannot be reasonably foreseen until the presentation of evidence at trial.

Plaintiff reserves the right to withdraw the designation of any expert who avers positively 

that any such previously designated expert will not be called as a witness at trial, and to redesignate them as a consulting expert.

Plaintiff reserves the right to elicit any expert opinion or lay opinion testimony at the time 

of trial that would be of benefit to the jury to determine material issues of fact so long as eliciting 

testimony would not be in violation of any existing Court Order, the Federal Rules of Civil 

Procedure, or the Federal Rules of Evidence.

Plaintiff reserves the right to elicit technical or other specialized knowledge or expert 

opinion testimony through direct or cross examination from potential fact witnesses based on the 

witnesses’ knowledge, skill, experience, training, or education, and concerning the subject of the 

witnesses’ personal knowledge and involvement in the matters at issue.

Plaintiff reserves the right to designate as an expert witness all medical providers who have 

treated any party for the injuries made the basis of this suit and/or any physical condition/injuries 

that occurred prior to or subsequent to the incident in question that may be relevant to any party’s 

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claims.

Plaintiff reserves the right to designate as an expert witness all investigators, witnesses, 

and or any other person who investigated, witnessed, or was present at the scene of the collision 

should the individual’s experience and background support their expert testimony and their 

opinions would be useful to the trier of fact to determine material issues of fact.

Respectfully submitted,

Paul L. Sadler

FBN: 17512400

Crystal S. Sadler 

SBN: 24103911

SADLER & SADLER 

Of counsel with Carabin Shaw, PC

8100 Broadway, Suite 200

San Antonio, Texas 78209

T: 210-908-7000

F: 210-200-8695

ps@sadlerandsadler.com

css@sadlerandsadler.com

e-service: service@sadlerandsadler.com

Attorneys for Plaintiff

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument was filed via the 

Court’s ECF system and caused to be served on all parties through counsel of record pursuant to 

the Federal Rules of Civil Procedure on the 2

nd day of June, 2021.

Leonard R. (Bud) Grossman 

BudG@CTHGlawfirm.com

Jonathan Galley 

SBN 24074243

ATTORNEYS FOR DEFENDANTS,

CAMERON LOGISTICS, LLC

and IBN UTHMAN KEARSE

Attorneys for Defendant 

Case 7:20-cv-00113-RCG Document 21 Filed 06/02/21 Page 7 of 8
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PAUL L. SADLER

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