FELLNER v. TRI-UNION SEAFOODS, L.L.C.

Filing 71

Letter from Plaintiff, Fellner. (Attachments: # 1 Exhibit A)(PACIORKOWSKI, THOMAS)

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Donglas A.. Prutton, Esq.
State Bar No. 118300
LAW OFFICES OF DOUGLAS A.. PRUTTON
1866 Clayton Road, Suite 211
Concord, CA 94520
[phone]
Ph:
Fax: [phone]
Attorney for Plaintiff
Jason Renshaw

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

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COUNTY OF CONTRA COSTA

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CASE NO. C04-01l30

JASON RENSHAW,
Plaintiff,

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PLAINTIFF'S EXPERT WITNESS LIST

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AND DECLARATION

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vs.

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TRI-UNION SEAFOODS, LLC, et al.,

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Defendants.

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I________________________~I

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Pursuant to Code of Civil Procedure § 2034, plaintiff Jason Renshaw hereby provides a

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list of the names and addresses of those persons whose expert opinion plaintiff may offer at the

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trial of this action.

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III

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Plaintiff'JBxpcrt Witnm li,t and Declaration

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COS!

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(J) Ron Kennedy, M. D.
2448 Guereville Rd., Sulte 800
Santa Rosa, CA 95401

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(2) Carl R. Corrigan, M. D.
Kaiser Pennanente
3400 Delta Fair Blvd.
Antioch, CA 94509

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(3) Steven M. Fredman, M. D.
Kaiser Permanente
1425 S.lvfain Street
Walnut Creek, CA 94596

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(4) Theodore R. Levin, M. D.
Kaiser Pennanente
1425 S. Main Street
Wainut Creek, CA 94596

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(5) Jane Hightower, M. D.
2100 Webster Street, Suite 418
San Francisco, CA

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DECLARATION

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All of the persons listed above have been plaintiff's treating physicians. They

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have not been retained by plaintiff to render expert opinions, except that plaintiff intends

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to retain Dr. Hightower to render expert opiulons. Dr. Hightower is a medical doctor

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licensed in the State of California with a specialty in internal medicine. She received her

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rp.edical degree from the University of Illinois at Chicago Medical School in 1988 and

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performed her residency at St. Mary's Hospital and Medical Center in San Francisco,

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California. AB part of her private practice, Dr. Hightower has performed extensive

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Plaintiff! E~perl WitneIl ria and Declaration

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research and clinical studies regarding mercury poisoning and the dangers of mercury in

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fish. It is expected that slie will testifY in the present case regarding Jason Renshaw's

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symptoms and conditions, the relationship between those symptoms and conditions and

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his ingestion of canned tuna, and the general dangers of mercury in. canned tuna. Dr.

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Hightower has been on an extended vacation and, thus, has not yet specifically advised

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plaintiff s counsel that she has agreed to testifY at triaL Dr. Hightower is sufficiently

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familiar with the pending case to provide a meaningful oral deposition concerning the

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specific testimony she is expected to give at trial, including any opinions and their bases.

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[t is expected that Dr. Hightower will be back from vacation on Monday, September 12,

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2005 and plaintiff's counsel will advise defendant's counsel at that time about Dr.

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Hightower's fees.

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I declare: under penalty of perjury under the laws of the State of California that the

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foregoing statements are true and correct

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LAW OFFICES OF DOUGLAS A. PRUTTON

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Dated: September 6, 2005

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L1~~
Dougl!s
Prutton
Attoti\ey £ r Plaintiff Jason Renshaw

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PlaintiffI J3xpert Witness List aJtd Declorafion

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COSI

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