IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

EL PASO DIVISION

KEILA ALMANZAR

Plaintiff

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CIVIL ACTION: 3:20-cv-00117-KC

DANIEL ANDRE EAGLESTAR, 

SHAMROCK FOODS, CO. and JORGE 

AVITIA

Defendants

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JURY DEMANDED

PLAINTIFF’S DESIGNATION OF EXPERTS AND 

DISCLOSURE OF EXPERT TESTIMONY

TO THE HONORABLE JUDGE KATHLEEN CARDONE:

1. COMES NOW KEILA ALMANZAR, hereinafter referred to as “Plaintiff”, and pursuant 

to the Order Granting Agreed Motion to Modify Amended Scheduling Order dated June 17, 2021

(Doc. 53), the Federal Rules of Civil Procedure and the Local Rules, files this her Designation of 

Experts and for such designation, would respectfully show unto the Court as follows:

I.

RETAINED EXPERTS

2. Plaintiff hereby designates the following individuals as retained testifying experts:

D. Liz Vinton

Nurse Practitioner

Texas Life Care Planning, LLC

6541 Kenwood Avenue

Dallas, Texas 75214

214-300-8060

liz@texaslifecareplanning.com

Case 3:20-cv-00117-KC Document 56 Filed 07/31/21 Page 1 of 6
Liz Vinton may be called to testify as to (1) Plaintiff’s medical diagnosis, (2) past and future 

medical treatment for such diagnosis and conditions, (3) Plaintiff’s future medical treatment and 

cost estimate, and (4) Plaintiff’s pain and suffering.

Any necessary report, curriculum vitae, testifying history and statement of compensation will be 

produced to Defendants. 

II.

NON-RETAINED TESTIFYING EXPERTS

3. Plaintiff also designates the following individuals who are not retained or specially 

employed to provide expert testimony but who may be called to offer opinions at trial:

Amanda M. Pacheco #3285

El Paso Police Department

Westside Regional Command Center

300 N. Campbell

El Paso, Texas 79901

915-212-8581

Officer Pacheco may testify regarding the investigation of the scene of the collision made the basis 

of this lawsuit, the damage sustained to the vehicles involved, and the injuries sustained by 

Plaintiff. She is also expected to offer testimony as to the Texas Transportation Code, Defendants’

violations of such code and the cause of the crash. For a brief summary and basis of Officer 

Pacheco’s mental impressions and opinions, please see her Texas Peace Officer’s Crash Report.

Dr. Philip Rodriguez, F.N.P., D.C.

First Class Medical Clinics

1030 Zaragoza Road, Ste. A

El Paso, Texas 79907

915-307-4444

It is anticipated that Dr. Rodriguez may testify generally in the area of general medicine, 

rehabilitation, physical therapy, and as to the injuries sustained by Plaintiff as a result of the crash 

made the basis of this lawsuit. It is expected that Dr. Rodriguez will testify as to the diagnosis, 

care and treatment rendered to Plaintiff as a result of the incident made the basis of this suit and 

his prognosis and future medical care. Employees and personnel, including the custodian of 

records, are expected to testify and/or offer an affidavit as to the reasonableness and necessity of 

Plaintiff’s past medical expenses as well as authenticity of Plaintiff’s medical records. For a brief 

summary and basis of Dr. Rodriguez’s mental impressions and opinions, please see the medical 

and billing records from First Class Medical Clinics.

Richard Anguiano, M.D.

Case 3:20-cv-00117-KC Document 56 Filed 07/31/21 Page 2 of 6
Southwest X-Ray

10501 Gateway West, Suite 140

El Paso, Texas 79925

915-544-7300

It is anticipated that Dr. Anguiano may testify generally in the area of radiology and as to the 

injuries sustained by Plaintiff as a result of the crash made the basis of this lawsuit. It is expected 

that Dr. Anguiano will testify as to the diagnosis, care and treatment rendered to Plaintiff as a result 

of the incident made the basis of this suit and his prognosis and future medical care. Employees 

and personnel, including the custodian of records, are expected to testify and/or offer an affidavit 

as to the reasonableness and necessity of Plaintiff’s past medical expenses as well as authenticity 

of Plaintiff’s medical records. For a brief summary and basis of Dr. Anguiano’s mental 

impressions and opinions, please see the medical and radiological records from Southwest X-Ray.

Dr. Donald J. Ammon

Juan Rivas

1

st Choice Treatment Clinic

6300 Gateway Blvd East

El Paso, Texas 79905

915-781-2273

It is anticipated that Dr. Ammon may testify generally in the area of general medicine, 

rehabilitation, chiropractic care and as to the injuries sustained by Plaintiff as a result of the crash 

made the basis of this lawsuit. It is expected that Dr. Ammon will testify as to the diagnosis, care 

and treatment rendered to Plaintiff as a result of the incident made the basis of this suit and his 

prognosis and future medical care. Employees and personnel, including the custodian of records, 

are expected to testify and/or offer an affidavit as to the reasonableness and necessity of 

Plaintiff’s past medical expenses as well as authenticity of Plaintiff’s medical records. For a brief 

summary and basis of Dr. Ammon’s mental impressions and opinions, please see the medical and 

billing records from 1

st Choice Treatment Clinic.

Bratislav Velimirovic, MD

4532 North Mesa Street

Ste. B2

El Paso, Texas 79912

915-247-3150

It is anticipated that Dr. Velimirovic may testify generally in the area of general and neurosurgery

and as to the injuries sustained by Plaintiff as a result of the crash made the basis of this lawsuit. It 

is expected that Dr. Velimirovic will testify as to the diagnosis, care and treatment rendered to 

Plaintiff as a result of the incident made the basis of this suit and his prognosis and future medical 

care. Employees and personnel, including the custodian of records, are expected to testify and/or 

offer an affidavit as to the reasonableness and necessity of Plaintiff’s past medical expenses as 

well as authenticity of Plaintiff’s medical records. For a brief summary and basis of Dr. 

Velimirovic’s mental impressions and opinions, please see his medical and billing records.

Case 3:20-cv-00117-KC Document 56 Filed 07/31/21 Page 3 of 6
4. Plaintiff does not concede that any expert designation, report or disclosure is required for 

the potential testimony of the non-retained individuals identified above, either under the Rules or 

any order of this Court, but such designation is provided out of an abundance of caution.

5. Plaintiff reserves the right to call any expert designated by Defendant or called by 

Defendant at hearing or trial. 

6. Plaintiff further reserves the right to solicit testimony from any person identified by any 

party as a fact witness in this case, which may require such witness to rely upon their specialized 

knowledge, training, experience, education, or expertise in a particular field or which may be 

considered “opinion” testimony. It is expected that such persons and any non-retained persons 

would provide testimony consistent with any and all records they have generated and/or any 

testimony or statements provided to any person or party and within the realm of their expertise and 

training.

7. Plaintiff may also solicit expert testimony from any party in this case. It is expected that 

any opinions solicited from such parties would be opinions provided within the realm of their 

expertise and consistent with their business records and/or consistent with deposition testimony or 

statements provided on such subjects.

8. Plaintiff reserves the right to supplement this designation. Plaintiff reserves the right to 

designate additional experts and Plaintiff’s experts reserve the right to supplement, amend or 

modify any of the opinions expressed in their reports as additional information may become 

available through discovery and at trial.

9. Plaintiff reserves the right to solicit testimony from any witness, lay or otherwise, who 

may have relevant opinions within the realms of their expertise.

Case 3:20-cv-00117-KC Document 56 Filed 07/31/21 Page 4 of 6
Respectfully submitted,

/s/ Veronica Sepulveda Martinez

Veronica Sepulveda Martinez

State Bar No. 24081144 

P.O. Box 4134 

Edinburg, TX 78540 

Telephone No.: 956/335-4900 

Telecopier No.: 956/338-5700 

veronica@garzamartinezlaw.com

ATTORNEY-IN-CHARGE FOR 

PLAINTIFF

Of Counsel:

I. Cecilia Garza

504 E. 9th Street, Ste. A

Mission, Texas 78572

Telephone: 956/335-4900

Telecopier: 956/338-5700

Email: cecilia@garzamartinezlaw.com

GARZA MARTINEZ, LLP

504 E. 9th Street, Ste. A

Mission, Texas 78572

Telephone: 956/335-4900

Telecopier: 956/338-5700

Email: office@garzamartinezlaw.com

Case 3:20-cv-00117-KC Document 56 Filed 07/31/21 Page 5 of 6
CERTIFICATE OF SERVICE

I certify that a true copy of the foregoing document was served on each attorney of record 

or party through CM/ECF filing on this the 31st day of July 2021:

Chris C. Pappas

Roland G. Hamilton

KANE RUSSELL COLEMAN LOGAN PC

5051 Westheimer Road, 10th Floor

Houston, Texas 77056

Phone: 713.425.7400

Email: cpappas@krcl.com; rhamilton@krcl.com

ATTORNEYS FOR DEFENDANTS 

EAGLESTAR & SHAMROCK FOODS, CO.

/s/ Veronica Sepulveda Martinez

Veronica Sepulveda Martinez

Case 3:20-cv-00117-KC Document 56 Filed 07/31/21 Page 6 of 6