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As an associate in the Casualty Department, Angie represents a diverse range of clients in civil litigation, focusing on premises liability, auto liability, and other general liability matters.

Angie graduated early from Florida Atlantic University with a Bachelor of Arts in Political Science. During her undergraduate career, Angie wrote her honors thesis titled: Exploring the Effects of Prosecutorial Discretion on Sentencing. She graduated with her juris doctor from Nova Southeastern University Shepard Broad College of Law. During her law school career, she served as a bilingual article editor for the International Law Students’ Association Journal of International and Comparative Law. She wrote and published an article in ILSA’s Volume 28 Issue titled:  A Comparative & International Study of Laws & Regulations Protecting Against Sexual Crimes in the United States, Colombia, and Norway: Sexual Violence in the Military and Armed Forces.  As an intern with Florida Legal Aid, Angie provided guidance and legal assistance to victims of domestic violence. Further, she gained valuable experience as an intern with the Broward County Public Defender’s Office. She also participated in the Children and Families Law clinic as a certified legal intern where she offered representation in various family law matters with the supervision of the clinic director. 

Prior to joining the firm, Angie represented both plaintiffs and defendants in landlord-tenant, construction defect, commercial, and municipal matters. 

Outside of the practice of law, Angie enjoys spending time with her family.  

    • Nova Southeastern University Shepard Broad College of Law (J.D., cum laude, 2023)
    • Florida Atlantic University (B.A., magna cum laude, 2020)
    • Florida, 2023
    • U.S. District Court Southern District of Florida, 2025
    • U.S. District Court Middle District of Florida, 2025
    • Spanish (Fluent)
    • Florida State Bar Association, Young Lawyers Division
    • Obtained summary judgment in a foodborne-illness wrongful death case. The plaintiff brought a wrongful death action against multiple parties, including the seafood supplier, asserting that the Decedent died after consuming raw oysters containing vibrio vulnificus. Our attorneys represented the supplier and argued that there was no evidence the oysters were defective when they left the supplier’s control. Their expert provided an affidavit outlining the applicable harvesting, processing, and transportation standards and confirmed that the supplier met all relevant duties. Faced with this record, plaintiff’s counsel ultimately conceded that the evidence did not support a claim against the supplier. The Court granted summary judgment in the supplier’s favor. The case continues against the remaining defendants, who face multimillion-dollar demands.

Results

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Defense Digest

Limitations to Expert Testimony

December 1, 2025

Key Points:  An expert may not testify to matters that fall outside his or her area of expertise. Biomechanical engineers are generally qualified to opine about an accident’s forces and the general types of injuries those forces may generate.  Biomechanical engineers may not offer opinions regarding patient-specific causation without appropriate medical expertise.  Experts play a critical role in litigation. In cases where there is a dispute over whether the forces involved in an accident were sufficient to cause an alleged injury, biomechanical experts are especially valuable. These experts analyze human movement and applied forces to assist in accident reconstruction and injury mechanism analysis.  Under Section 90.702, Fla. Stat. (2025):  [A] witness qualified as an expert by knowledge, skill, experience, training, or education may testify about it in the form of an opinion or otherwise, if:  (1) The testimony is based upon sufficient facts or data; (2) The testimony is the product of reliable principles and methods; and (3) The witness has applied the principles and methods reliably to the facts of the case. The Fifth District Court of Appeal recently addressed the limits of biomechanical expert testimony in Clark v. Hahn, 401 So.3d 550, 551 (Fla. 5th DCA 2024), in which the plaintiff filed a lawsuit against Kermit and Evelyn Hahn for negligence.  The plaintiff alleged she suffered permanent injury as a result of a car accident. During the trial, the plaintiff requested that the court prohibit the defense expert from giving medical causation opinions. The defendants’ counsel assured the court that the biomechanical expert would not offer medical opinions.  However, during the trial, the biomechanical expert was asked whether the forces applied to the plaintiff’s spine could have produced the injury mechanisms at issue. The expert opined that the particular accident would not have generated the mechanisms necessary to cause an intervertebral disc herniation in the cervical spine in a person of the plaintiff’s height and weight, given the specific vehicle involved. The trial court overruled the plaintiff’s objection and permitted the testimony.  The jury ultimately found that the plaintiff did not suffer a permanent injury. The trial court denied the plaintiff’s motion for a mistrial, and the plaintiff appealed. On appeal, the Fifth District Court of Appeal reversed and remanded for a new trial, holding that the expert’s testimony exceeded the scope of his expertise. The District Court reasoned the expert testified to matters outside of his area of expertise by offering a patient-specific causation opinion. The biomechanical expert was not a medical doctor and, thus, not qualified to render such an opinion. The court explained, “While biomechanical experts may discuss the forces generated by an accident and how a hypothetical person’s body will respond to those forces they are not qualified to render medical opinions regarding the precise cause of a specific injury.” Biomechanical experts are not generally allowed to render opinions that require medical expertise, such as the permanency or severity of an injury. Such opinions require a medical evaluation of the patient, which is beyond the typical expertise of a biomechanical engineer. This limitation does not necessarily apply if the biomechanical engineer is also a medical doctor. Doctors retained as experts may testify as to specific causation.  The expert’s training, education, and certifications must be analyzed alongside their expected testimony to determine whether their opinions are beyond their expertise. In such cases, a Daubert motion must be timely filed to exclude the opinions that are outside of the expert’s scope. The Daubert standard stems from a United States Supreme Court case that outlines the trial courts’ role as the “gatekeepers” of expert testimony. Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (1993). The Daubert standard is codified in § 90.702, Fla. Stat. (2025), and requires the expert’s testimony to be both relevant and reliable. Understanding the limitations of an expert’s testimony plays a vital role in structuring litigation strategy. Clark reinforces a key evidentiary boundary for expert testimony. Biomechanical engineers may testify regarding the magnitude of accident forces and the general injury mechanisms such forces can produce. However, biomechanical engineers may not cross into medical causation opinions without the appropriate medical qualifications. The case also highlights the importance of timely objecting to improper expert testimony.   Defense Digest, Vol. 31, No. 4, December 2025, is prepared by Marshall Dennehey to provide information on recent legal developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. ATTORNEY ADVERTISING pursuant to New York RPC 7.1. © 2025 Marshall Dennehey. All Rights Reserved. This article may not be reprinted without the express written permission of our firm. For reprints, contact tamontemuro@mdwcg.com.

Firm Highlights

Thought Leadership

WCJ Improperly Refused to Conduct C&R Hearing and Erroneously Required Settlement of All Pending Petitions

In this case, the claimant sustained injuries in the course and scope of her employment as a registered nurse. The employer acknowledged the injury by a Notice of Compensation Payable (NCP).  Subsequently, a Workers’ Compensation Judge (WCJ) expanded the description of injury. The employer then filed a Termination Petition, alleging the claimant was fully recovered from the injuries. Providers filed Utilization Review (UR) Petitions, challenging UR determinations finding their chiropractic treatment to be not reasonable and necessary. A settlement of the claim was eventually reached, and the employer filed a Petition to Seek Approval of a Compromise and Release (C&R) Agreement. The C&R outlined that the agreement fully resolved all future workers’ compensation claims except for the termination and UR Petitions. Briefs were filed and one day later, the WCJ issued an Interlocutory Order which stated if instructions were not followed regarding filing of a C&R, a settlement hearing date would not be given. The employer complied with the order, and filed the C&R. Subsequently, the WCJ notified the parties that the C&R must resolve all issues in the petitions, or would not be entertained. A settlement hearing was never held, and the WCJ then issued a decision, granting the Termination Petition and dismissing the UR Petitions. The WCJ also said that the Petition for Approval of a C&R was dismissed without prejudice, as the issues in the Termination and UR Petitions went to a decision. The claimant appealed to the Workers’ Compensation Appeal Board (Board). The Board granted the claimant’s appeal, finding that the WCJ violated the requirement of Section 449 that an expedited hearing be held when a Petition for Approval of a C&R is filed.  The Board further held that it was legally incorrect for the WCJ to insist that the C&R resolve all issues raised by the pending Petitions. The Board remanded the case to a new WCJ, and Employer appealed to the Commonwealth Court. The court affirmed the Board and held that the WCJ erred, as a matter of law, by refusing to hold an expedited hearing within 30 days, once the Petition for Approval of a C&R was filed.  The court noted that the language of Section 449(b) is mandatory, and a settlement hearing is not discretionary or dependent on a party’s separate request for a stay, or whether the record has been closed. The court further rejected Employer’s argument that the case should not be remanded to a new WCJ for a new decision on the termination and and UR Petitions, as the Board passed no judgment on whether the C&R Agreement resolved the termination and UR Petitions, and left it for the WCJ to decide in connection with the Petition for Approval of a C&R.

Thought Leadership

Appellate Division Reversed Trial Judge's Orders Granting a Plaintiff's Section 40 Summary Judgement Motion

In Haskins v. Casey, et al., the plaintiff Dane Haskins worked for defendant Ekornes, Inc. (Ekornes) as a material handler. In June 2021, he filed a workers’ compensation claim petition for benefits due to a left shoulder injury in December 2020. He then resolved his workers’ compensation claim in November 2022 under an Order Approving Settlement. In January 2023, he filed a lawsuit against Ekornes and later amended to add additional claims and name other defendants, including the Ekornes president, chief financial officer, and director of human resources. In May 2025, a second amended complaint alleged that after he filed the workers compensation claim, Ekornes placed him on leave under the Family and Medical Leave Act (FMLA), denied his request for a work accommodation, and ultimately terminated him from employment in December 2021. He pleaded several causes of action asserting violations of the New Jersey Law Against Discrimination (LAD) as well as fraudulent concealment and wrongful discharge. The plaintiff then moved for partial summary judgment, seeking an order enforcing Section 40 of the Workers’ Compensation Act (WCA) as well as summary judgment on his FMLA claims. The defendants opposed the motions and cross-moved for summary judgment on the FMLA claims. After arguments, the court entered an order in December 2025, denying the FMLA motion and cross motion and granting the plaintiff’s Section 40 motion. In the order, the court permitted the plaintiff to pursue compensatory damages at trial in connection with the bodily injury claim. The court also allowed the plaintiff to present evidence of any workers’ compensation benefits to support his claim. The court then denied the defendant's subsequent reconsideration motion in February 2026. The defendants that appealed the Section 40 aspect of the orders. In reviewing the appeal de novo, the Appellate Division rejected the plaintiff's argument that the work-related injury arose out of his discrimination claims under the LAD. The plaintiff argued that he should be able to pursue a personal injury claim as a part of his LAD claim, noting that the employer’s compensation carrier would be able to assert a lien against any recovery against his LAD claims. In distinguishing between the Richter vs. Oakland Board of Education, 246 N.J. 507 (2021) case, in which the Court found that any recovery would be subject to a Section 40 lien as the allegation was that the defendants failed to accommodate her pre-existing diabetic condition, which resulted in bodily injury. In this case, the Appellate Division indicated that there was no bodily injury caused by Ekornes’ failure to accommodate a pre-existing disability. Rather, the shoulder injury was a result of a workers compensation claim, for which he received appropriate benefits previously. The Appellate Division noted that if the plaintiff was successful in proving his LAD claims, he would be entitled to damages caused by the discriminatory discriminatory conduct such as lost wages and emotional distress damages and that there will be no Section 40 lien. In addition, the Appellate Division disagreed that the petitioner could present evidence about and seek damages for his shoulder injury at trial. Although the petitioner argued that a defendant who retaliated against an employee for filing a workers’ compensation claim should not benefit from the exclusivity provision of the WCA, the Appellate Division noted that the Legislature did not include this type of scenario in the statue nor did any of the case law recognize this type of claim as a remedy. As such, the Appellate Division reversed the December 2025 order granting the the plaintiff’s Section 40 summary judgment motion as well as the February 2026 reconsideration motion order. The Appellate Division noted that they did not intend to limit the plaintiff in his pursuit of his other claims on under the LAD, FMLA, and workers’ compensation retaliation causes of action.

Thought Leadership

Commonwealth Court Reaffirms the Constitutionality of Act 111's IRE Provisions

In this case, the claimant sustained a work injury of January 6, 1994, which was acknowledged by Notice of Compensation Payable (NCP). After the claimant’s receipt of 104 weeks of temporary total disability benefits, the employer filed a Request for an Impairment Rating Examination (IRE). The IRE was performed in May 2023 and the IRE physician found that the claimant had a 5% whole person impairment, under the AMA Guides. The employer filed a Petition based on the IRE results, and the Petition was granted by the WCJ. During litigation, the claimant argued that the IRE provisions of Act 111 (Section 306(a.3) of the Act) were not applicable to her injury, since it predated June 24, 1996, the date Act 57 went into effect, and that the IRE provisions were unconstitutional. The Workers’ Compensation Judge (WCJ)) granted the Petition and the Board affirmed. On appeal to the Commonwealth Court, the claimant argued that Act 111 violated the nondelegation doctrine and that its retroactive application to the claimant’s injury was unconstitutional. The court rejected the arguments on the basis that they had already found the same arguments without merit in multiple, prior cases. The court also addressed an argument made by the claimant that Act 111 was procedurally defective under the Pennsylvania Constitution because it was only considered on two days in each House after having undergone amendments and reassignments. The court noted that the Pennsylvania Constitution requires every bill to be considered on three different days in each House. The claimant maintained that, according to the legislative history, the bill did not receive three separate days of consideration from each House when it was assigned a new bill number. The court pointed out, however, that the bill number, H.B. 1840 remained constant and was considered on three occasions by the House. Further, the court concluded that minor amendments to the bill were germane to its original subject, which was to modify the Act’s IRE process, in accordance with Protz II.