Hill, As Personal Representative Of The Estate Of Margaret Carlton Deceased, Chelsea Vs. Lopez, Leonel D.O.

PLAINTIFF’S OBJECTION TO NOTICE OF PRODUCTION OF NON PARTY AND/OR REQUEST FOR COPIES

DEFENDANTS, MARTIN MEMORIAL PHYSICIAN CORPORATION D/B/A MARTIN HEALTH PHYSICIAN GROUP AND MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL’S, EXPERT WITNESS DISCLOSURE

NOTICE OF DESIGNATION OF TRIAL EXPERTS

PLAINTIFF’S RESPONSE TO REQUEST FOR PRODUCTION OF DEFENDANTS, MICHAEL MALTMAN, M.D. DATED NOVEMBER 12, 2021:

DEFENDANTS, MARTIN MEMORIAL PHYSICIAN CORPORATION D/B/A MARTIN HEALTH PHYSICIAN GROUP AND MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, EXPERT REQUEST FOR PRODUCTION TO PLAINTIFF

DEFENDANTS, MARTIN MEMORIAL PHYSICIAN CORPORATION D/B/A MARTIN HEALTH PHYSICIAN GROUP AND MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, FACT WITNESS LIST

SENIOR JUDGE ASSIGNMENT ORDER - SOGMED 12.22.21

NOTICE OF PRODUCTION FROM NON PARTY

MICHAEL MALTMAN, M.D.’S AMENDED RESPONSE TO PLAINTIFF’S NORTHUP REQUEST TO PRODUCE

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PRECLUDE EVIDENCE OF FAILED EXAMINATIONS

DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, RESPONSE TO PLAINTIFF'S NORTHRUP REQUEST FOR PRODUCTION SERVED MARCH 2, 2022

MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP NOTICE OF FILING TRANSCRIPT OF DEPOSITION OF KRISTIN KUCSMA, VOLUME 1 (ATTACHED)

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION TO STRIKE THE TESTIMONY OF PLAINTIFF'S EXPERT ECONOMIST, KRIS KUCSMA:

PLAINTIFF’S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION OF SUSAN CORNWELL ON 04.04.2022

DEFENDANTS, MARTIN MEMORIAL PHYSICIAN CORPORATION CL/B/A MARTIN HEALTH PHYSICIAN GROUP AND MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, AMENDED EXHIBIT LIST:

DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, SUPPLEMENTAL RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS NO. 23 AND NO. 26:

PLAINTIFF’S 4TH AMENDED WITNESS LIST

MICHAEL MALTMAN, M.D.’S AMENDED RESPONSE TO PLAINTIFF’S NORTHUP REQUEST TO PRODUCE

NOTICE OF HEARING (VIA ZOOM): 04.01.2022 AT 11:00 AM ON DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP'S MOTIONS IN LIMINE

DEFENDANTS, MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, PLLC’S, NOTICE OF JOINDER IN MOTIONS IN LIMINE:

DEFENDANT, MICHAEL E. MALTMAN, M.D.,EXHIBIT LIST:

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PRECLUDE PLAINTIFF'S EXPERT PATHOLOGIST, DR. EROSTON PRICE, FROM TESTIFYING AS TO THE CLINICAL CARE AND TREATMENT OF MARGARET CARLTON OR THE STANDARD OF CARE THAT PERTAINS TO ANY HEALTHCARE PROVIDER

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PROHIBIT PLAINTIFF'S EXPERTS FROM COMMENTING ON THE OPINIONS OF OTHER EXPERTS

DEFENDANT, MICHAEL E. MALTMAN, M.D.,2ND AMENDED EXHIBIT LIST:

DEFENDANTS, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S,SECOND AMENDED EXHIBITLIST

DEFENDANT, MICHAEL E. MALTMAN, M.D., AMENDED EXHIBIT LIST

DEFENDANTS, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC'S, REQUEST FOR COPIES TO CO-DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER D/B/A CLEVELAND CLINIC TRADITION HOSPITAL

PLAINTIFF’S MOTION FOR ENLARGEMENT OF JURY PANEL

DEFENDANTS’, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC, NOTICE OF JOINDER REGARDING MOTIONS IN LIMINE

DEFENDANTS, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC'S, REQUEST FOR COPIES TO CO-DEFENDANT, MICHAEL E. MALTMAN, M.D.

DEFENDANTS, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC'S NOTICE OF SERVING ANSWERS TO PLAINTIFF'S NORTHRUP INTERROGATORIES:

DEFENDANTS, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S AMENDED RESPONSE TO PLAINTIFF’S NORTHRUP REQUEST TO PRODUCE

DEFENDANTS, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S NOTICE OF SERVICEOF AMENDED ANSWERS TO PLAINTIFF’S NORTHRUP INTERROGATORIES

MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, PLLC’S NOTICE OF SERVINGAMENDED ANSWERS TO PLAINTIFF’S NORTHUP INTERROGATORIES

PLAINTIFF’S EXCLUSIONARY MOTION IN LIMINE

DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC. CL/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, NOTICE OF SERVING ANSWERS TO PLAINTIFF'S NORTHRUP INTERROGATORIES SERVED MARCH 2, 2022

NOTICE TO PRODUCE COPIES OF DOCUMENTS

NOTICE OF SERVING IMPEACHMENT INTERROGATORIES

MICHAEL MALTMAN, M.D.’S NOTICE OF SERVING AMENDED ANSWERS TO PLAINTIFF’S EXPERT INTERROGATORIES:

MICHAEL MALTMAN, M.D.’S AMENDED RESPONSE TO PLAINTIFF’S EXPERT REQUEST TO PRODUCE:

CROSS-NOTICE OF TAKING DEPOSITION OF KRIS KUCSMA 3.18.22 (DEPOSITION TO BE TAKEN REMOTELY VIA ZOOM):

DEFENDANTS’, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC, NOTICE OF TRIAL CONFLICTS:

COURT MINUTES: 4/1/2022: 11:00AM: DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP'S MOTIONS IN LIMINE

DEFENDANTS, LEONEL LOPEZ, D.O. AND PARAGONCONTRACTINGSERVICES, LLC’S,AMENDED EXHIBITLIST

MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, PLLC’S NOTICE OF SERVING ANSWERS TO PLAINTIFF’S NORTHUP INTERROGATORIES

MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP NOTICE OF FILING TRANSCRIPT OF DEPOSITION OF KRISTIN KUCSMA, VOLUME 2 (ATTACHED)

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PRECLUDE REFERENCE TO MR. AND MRS. CARLTON'S RELIGIOUS BELIEFS

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PRECLUDE PLAINTIFF FROM COMMENTING ON THE FAILURE OF A WITNESS TO TESTIFY

COURT MINUTES - DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP'S MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/I3/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE REGARDING REFERENCE TO AUTHORITATIVE TEXTS

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. DAB/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTIONS IN LIMINE

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PRECLUDE JOE HILL FROM TESTIFYING TO THE STANDARD OF CARE THAT PERTAINS TO TREATING HEALTHCARE PROVIDERS OR RENDERING CAUSATION OPINIONS

AGREED ORDER ON PLAINTIFF’S AMENDED OMNIBUS MOTION IN LIMINE FILED ON MARCH 23, 2022; SIGNED 03.25.2022

NOTICE OF FILING AUTHORITY:

PLAINTIFF’S SECOND RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM:

DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP 'S MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY:

DEFENDANTS, MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, PLLC’S, NOTICE OF JOINDER:

DEFENDANT MARTIN MEMORIAL MEDICAL CENTER, INC.'S D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S CERTIFICATE OF NON-OBJECTION:

NOTICE OF HEARING 3.25.22 AT 11:45 AM (1HR) (ZOOM) 1) PLAINTIFF’S EXCLUSIONARY MOTION IN LIMINE 2) CASE MANAGEMENT CONFERENCE:

PLAINTIFF'S EXHIBIT LIST:

DEFENDANT’S RESPONSE TO PLAINTIFF’S SUPPLEMENTAL REQUEST TO PRODUCE:

PLAINTIFF’S MOTION REGARDING ENLARGED JURY PANEL, USE OF JUROR QUESTIONNAIRES AND JUROR RESEARCH:

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PRECLUDE PHOTOGRAPHS AND VIDEOS TAKEN BY DECEDENT'S FAMILY MEMBERS

PLAINTIFF’S NOTICE OF TAKING VIDEOTAPED DEPOSITION: SUSAN CORNWELL ON 04.01.2022

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PRECLUDE PLAINTIFF'S NURSING EXPERT, TABETHA RUPLE, R.N., FROM TESTIFYING TO THE STANDARD OF CARE THAT PERTAINS TO PHYSICIANS OR RENDERING CAUSATION OPINIONS

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PRECLUDE PLAINTIFF'S EXPERT, JOHN SCHWEIGER, M.D., FROM TESTIFYING AS TO THE STANDARD OF CARE REGARDING HUBERT GARCIA, M.D.

MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP NOTICE OF FILING TRANSCRIPT OF DEPOSITION OF TABETHA RUPLE, R.N.:

PLAINTIFF’S MOTION PERTAINING TO DEFENDANT’S MOTION FOR CASE MANAGEMENT IN CASE OF METZLER V. VALDES ET AL:

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PRECLUDE PLAINTIFF'S EXPERT, JOHN SCHWEIGER, M.D., FROM PROVIDING CUMULATIVE TESTIMONY

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PRECLUDE THE SUBMISSION OF PLAINTIFFS' EXPERTS' WRITTEN REPORTS INTO EVIDENCE

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, NOTICE OF SERVICE OF PROPOSAL FOR SETTLEMENT TO PLAINTIFF:

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. DA3/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PROHIBIT COUNSEL FROM MAKING REMARKS WHICH BOLSTER OR DIMINISH THE CREDIBILITY OF WITNESSES OR AUTHORITATIVENESS OF TEXTS

NOTICE OF CONFLICTS:

DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP'S, RESPONSE TO PLAINTIFF'S SECOND SUPPLEMENTAL REQUEST FOR PRODUCTION:

NOTICE OF HEARING 3.8.22 AT 11:00 AM (ZOOM) DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP'S MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY

RE-NOTICE OF HEARING 3.8.22 AT 11:00 AM (ZOOM) PLAINTIFF'S MOTION TO COMPEL:

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE REGARDING THE LIMITED SCOPE OF EXPERT TESTIMONY

DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP 'S, RESPONSE TO PLAINTIFF'S FOURTH SUPPLEMENTAL REQUEST FOR PRODUCTION:

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO LIMIT AND EXCLUDE THE AUTOPSY PHOTOGRAPHS

ORDER ON PLAINTIFF’S ORE TENUS MOTION TO DISPENSE WITH MEDIATION; SIGNED 03.22.2022

DEFENDANTS', MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP, MOTION IN LIMINE TO PRECLUDE EVIDENCE OF THE AUDIT TRAIL OR PHOTOGRAPHS OF THE ONSITE MEDICAL RECORD INSPECTION

AGREED ORDER ON PLAINTIFF’S MOTION TO ALLOW JURY QUESTIONNAIRESAND FOR PRE-QUALIFICATION OF JURORS; SIGNED 03.18.2022

NOTICE OF COMPLIANCE

RESPONSE TO REQUEST TO PRODUCE

DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC.'S D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, REQUEST FOR COPIES TO PLAINTIFF:

AGREED ORDER ON PLAINTIFF’S ORE TENUS MOTION FOR ENLARGEMENT OF JURY PANEL; SIGNED 03.18.2022

DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, NOTICE OF SERVING ANSWERS TO PLAINTIFF'S SECOND SUPPLEMENTAL INTERROGATORIES SERVED FEBRUARY 14, 2022

DEFENDANT MARTIN MEMORIAL MEDICAL CENTER, INC.'S D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S CERTIFICATE OF NON-OBJECTION

DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP'S, RESPONSE TO PLAINTIFF'S THIRD SUPPLEMENTAL REQUEST FOR PRODUCTION

PLAINTIFF’S RESPONSE TO SECOND SUPPLEMENTAL REQUEST TO PRODUCE OF MARTIN MEMORIAL MEDICAL CENTER:

PLAINTIFF’S OBJECTION TO NOTICE OF PRODUCTION OF NON PARTY AND/OR REQUEST FOR COPIES:

DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP 'S, AMENDED RESPONSE TO PLAINTIFF'S SECOND SUPPLEMENTAL REQUEST FOR PRODUCTION:

PLAINTIFF’S AMENDED EXHIBIT LIST

DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP'S, RESPONSE TO PLAINTIFF'S SUPPLEMENTAL REQUEST FOR PRODUCTION

ORDER ON DEFENDANT, MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, PLLC’S MOTION TO COMPEL BETTER ANSWERS TO INTERROGATORIES; SIGNED 2.24.2

DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP'S, RESPONSE TO CO-DEFENDANT, MICHAEL E. MALTMAN, M.D.'S, REQUEST TO PRODUCE

NOTICE OF PRODUCTION FROM NON PARTY:

PLAINTIFF’S OBJECTION TO NOTICE OF PRODUCTION OF NON PARTY AND/OR REQUEST FOR COPIES:

DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, NOTICE OF SERVING ANSWERS TO PLAINTIFF'S SUPPLEMENTAL INTERROGATORIES SERVED JANUARY 23, 2021

DEFENDANTS, MARTIN MEMORIAL PHYSICIAN CORPORATION D/B/A MARTIN HEALTH PHYSICIAN GROUP AND MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, SECOND SUPPLEMENTAL REQUEST FOR PRODUCTION TO PLAINTIFF:

PLAINTIFF’S NOTICE OF SERVICE OF NORTHRUP INTERROGATORIESTO ALL DEFENDANTS

NOTICE OF PRODUCTION FROM NON PARTY

DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC.'S D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, REQUEST FOR COPIES TO PLAINTIFF

PLAINTIFF’S NORTHRUP REQUEST TO PRODUCE TO ALL DEFENDANTS:

PLAINTIFF’S THIRD SUPPLEMENTAL REQUEST FOR PRODUCTION TO DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC.,D/B/A CLEVELAND CLINIC TRADITION HOSPITAL:

DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP'S, NOTICE OF SERVICE OF AMENDED ANSWERS TO PLAINTIFF'S EXPERT INTERROGATORIES

DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP 'S, AMENDED RESPONSE TO PLAINTIFF'S EXPERT REQUEST TO PRODUCE

NOTICE OF UNAVAILABILITY: THOMAS G. AUBIN (AUGUST 23, 2022 THROUGH AUGUST 29, 2022)

PLAINTIFF’S CROSS-NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM(TO ADD VIDEO):

DEFENDANT MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S NOTICE OF COMPLIANCE WITH ORDER ON PLAINTIFF'S MOTION TO COMPEL COPIES OF NON-PARTY PRODUCTION RECORDS:

PLAINTIFF’S OBJECTION TO NOTICE OF PRODUCTION OF NON PARTY AND/OR REQUEST FOR COPIES

DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, NOTICE OF SERVING AMENDED ANSWER TO PLAINTIFF'S INTERROGATORY NO. 11 SERVED WITH THE COMPLAINT:

NOTICE OF DEPOSITION DUCES TECUM (EXHIBIT NOT ATTACHED):

PLAINTIFF’S RESPONSE TO REQUEST FOR PRODUCTION OF DEFENDANT, MICHAEL MALTMAN, M.D.:

DEFENDANTS, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S NOTICE OF SERVING ANSWERS TO PLAINTIFF’S EXPERT WITNESS INTERROGATORIES TO PLAINTIFF

PLAINTIFF’S NOTICE OF VIDEOTAPED INSPECTION DUCES TECUM OF ELECTRONIC CHART OF MARTIN MEMORIAL MEDICAL CENTER 2.28.22

NOTICE OF COMPLIANCE

PLAINTIFF’S AMENDED NOTICE OF TAKING VIDEOTAPED DEPOSITION SUBPOENA DUCES TECUM OF MICHAEL MALTMAN, M.D. ON 02.11.2022

NOTICE OF PRODUCTION FROM NON PARTY-RECORDS CUSTODIAN OF:JAYNA PATE

ORDER ON PLAINTIFF’S MOTION TO COMPEL AND CASE MANAGEMENT; SIGNED 2.15.22:

PLAINTIFF’S NOTICE OF SERVICE OF SECOND AMENDED ANSWERS TO INTERROGATORIES OF DEFENDANTS, MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, LLC:

PLAINTIFF’S OBJECTION TO NOTICE OF PRODUCTION OF NON PARTY AND/OR REQUEST FOR COPIES:

PLAINTIFF’S MEMORANDUM OF LAW ON VOIR DIRE AND REASONABLE TIME TO RESEARCH PROSPECTIVE JURORS:

ORDER ON PLAINTIFF’S MOTION TO COMPEL COPIES OFNON-PARTY PRODUCTION RECORDS; SIGNED 2.15.22:

ORDER ON PLAINTIFF’S MOTION TO INSPECT ELECTRONIC CHART; SIGNED 2.15.22:

REQUEST TO PRODUCE

PLAINTIFF’S NOTICE OF COMPLIANCE WITH REQUEST FOR COPIES:

DEFENDANT MARTIN MEMORIAL MEDICAL CENTER, INC.'S D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S REQUEST FOR COPIES TO CO-DEFENDANT, MICHAEL E. MALTMAN, M.D.:

DEFENDANTS,LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S SECOND AMENDED LIST OF EXPERT WITNESSES:

NOTICE OF TAKING DEPOSITION OF ROBERT HOLLOWAY, M.D. ON 03.10.2022

DEFENDANT MARTIN MEMORIAL MEDICAL CENTER, INC.'S D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S CERTIFICATE OF NON-OBJECTION

CROSS-NOTICE OF TAKING DEPOSITION (DEPOSITION TO BE TAKEN REMOTELY VIA ZOOM):

PLAINTIFF’S NOTICE OF PRODUCTION FROM NON PARTY

PLAINTIFF’S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM 3.2.22:

NOTICE OF PRODUCTION FROM NON PARTY

PLAINTIFF’S NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM OF SHARON COFFEY 3.1.22:

PLAINTIFF’S NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM OF ALISA SMITH RN 3.11.22:

PLAINTIFF’S CERTIFICATE OF NO OBJECTIONS

COURT MINUTES - 2.10.22 AT 9:00AM

DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, RESPONSE TO PLAINTIFF'S EXPERT REQUEST TO PRODUCE TO ALL DEFENDANTS:

NOTICE OF AVAILABILITY: THOMAS G. AUBIN

MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL; AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP NOTICE OF TRIAL CONFLICT:

NOTICE OF AVAILABILITY: THOMAS G. AUBIN

ORDER STRIKING CASE FROM DOCKET CALL AND SPECIALLY SETTING TRIAL- 4.18.22- 4.22.22 AND 4.25.22- 4.29.22 AT 9:00 AM; SIGNED 1.5.22:

DEFENDANTS,LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S LIST OF EXPERT WITNESSES:

CERTIFICATE OF NON-OBJECTION:

PLAINTIFF’S NOTICE OF PRODUCTION FROM NON-PARTY

DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, NOTICE OF SERVICE OF ANSWERS TO PLAINTIFF'S EXPERT INTERROGATORIES:

DEFENDANT, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S RESPONSES TO PLAINTIFF’S EXPERT REQUEST TO PRODUCE TO ALL DEFENDANTS

PLAINTIFF’S NOTICE OF SERVING ANSWERS TO EXPERT WITNESS INTERROGATORIES:

PLAINTIFF’S NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM OF LAURENCE SANDS, M.D. 3.25.22:

CROSS-NOTICE OF TAKING DEPOSITION OF RAMONA LOUTOS ON 03.09.2022

DEFENDANTS, MARTIN MEMORIAL PHYSICIAN CORPORATION D/B/A MARTIN HEALTH PHYSICIAN GROUP AND MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, EXHIBIT LIST:

PLAINTIFF'S NOTICE OF SERVICE OF EXPERT INTERROGATORIES TO ALL DEFENDANTS

DEFENDANTS LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S NOTICE OF TAKING REMOTE VIDEO CONFERENCE DEPOSITION DUCES TECUM VIA ZOOM OF MARC KAYE, M.D. ON 02.21.2022

NOTICE TO PRODUCE COPIES OF DOCUMENTS OBTAINED PURSUANT TO FLA. R. CIV. P., 1.351(C):

PLAINTIFF’S NOTICE OF SERVICE OF AMENDED ANSWERS TO INTERROGATORIES OF DEFENDANTS, MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, LLC:

PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM - MICHAEL STEVENS , M.D.

PLAINTIFF’S NOTICE OF PROPOUNDING SUPPLEMENTAL INTERROGATORIES TO DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL:

PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION SUBPOENA DUCES TECUM 2.11.22:

DEFENDANTS’, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC, NOTICE OF TRIAL CONFLICTS:

PLAINTIFF’S AMENDED RESPONSE TO REQUEST FOR PRODUCTION OF DEFENDANTS, MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, PLLC:

CROSS-NOTICE OF TAKING DEPOSITION OF DOUGLAS CARLTON ON 01.24.2022

PLAINTIFF’S NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM OF JONATHAN BERLIN, M.D. 3.16.22:

RE-NOTICE OF HEARING : 02.10.2022 AT 9:00 AM ON DEFENDANT’S MOTION TO COMPEL BETTER RESPONSES TO REQUEST TO PRODUCE AND BETTER ANSWERS TO INTERROGATORIES

NOTICE OF APPEARANCE:MICHAEL PETRUCCELLI, OF RUBENSTEIN LAW, P.A. ON BEHALF OF PLAINTIFF

PLAINTIFF’S NOTICE OF CONFLICT

NOTICE OF TAKING DEPOSITION DUCES TECUM-KRIS KUESMAN

NOTICE OF HEARING 2.10.22 AT 9:00 AM (ZOOM) 1) PLAINTIFF’S MOTION TO COMPEL 2) PLAINTIFF’S MOTION TO INSPECT CHART 3) PLAINTIFF’S MOTION FOR URGENT CASE MANAGEMENT CONFERENCE:

PLAINTIFF’S RESPONSE TO EXPERT REQUEST TO PRODUCE OF MARTIN MEMORIAL MEDICAL CENTER

AMENDED NOTICE OF TAKING DEPOSITION OF PLAINTIFFS’ SECOND MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT’S DISCOVERY REQUESTS ON 01.07.2022

NOTICE OF DEPOSITION DUCES TECUM OF JOHN SCHWEIGER, M.D 2.24.22:

PLAINTIFF’S NOTICE OF SERVING ANSWERS TO EXPERT WITNESS INTERROGATORIES

DEFENDANTS, MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC. D/B/A MARTIN HEALTH PHYSICIAN GROUP'S, MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF DR. HUBERT GARCIA:

PLAINTIFF’S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM 2.10.22:

NOTICE OF TAKING DEPOSITION DUCES TECUM:

DEFENDANTS LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S NOTICE OF TAKING REMOTE VIDEOCONFERENCE DEPOSITION DUCES TECUM VIA ZOOM OF MARC FARRAYE, M.D 2.22.22:

NOTICE OF TAKING DEPOSITION OF JOSEPH HILL 2.3.22

NOTICE OF TAKING DEPOSITION OF BRANDI HILL 2.3.22

NOTICE OF HEARING 2.2.22 9:00AM - PLAINTIFF'S MOTION TO INSPECT ELECTRONIC CHART:

DEFENDANTS, MARTIN MEMORIAL PHYSICIAN CORPORATION D/B/A MARTIN HEALTH PHYSICIAN GROUP AND MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, NOTICE OF SERVICE OF EXPERT WITNESS INTERROGATORIES TO PLAINTIFF

MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP NOTICE OF FILING TRANSCRIPT OF DEPOSITION OF DOUGLAS CARLTON:

PLAINTIFF’S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM OF JONATHAN BERLIN, M.D. 3.16.22:

MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP NOTICE OF FILING TRANSCRIPT OF DEPOSITION OF JOHN SCHWEIGER, M.D:

PLAINTIFF’S AMENDED EXCLUSIONARY MOTION IN LIMINE

PLAINTIFF’S SECOND AMENDED EXHIBIT LIST:

PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM OF DIANA HOFFMAN, RN ON 01.18.2022

PLAINTIFF’S RESPONSE TO BOECHER REQUEST FOR PRODUCTION OF DEFENDANTS, MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, PLLC:

PLAINTIFF’S NOTICE OF SERVING ANSWERS TO BOECHER INTERROGATORIES:

PLAINTIFF’S SUPPLEMENTAL REQUEST FOR PRODUCTION TO DEFENDANTS, MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, PLLC:

PLAINTIFF’S SECOND SUPPLEMENTAL REQUEST FOR PRODUCTION TO DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL

PLAINTIFF’S NOTICE OF PROPOUNDING SECOND SUPPLEMENTAL INTERROGATORIES TO DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL:

PLAINTIFF’S MOTION TO ALLOW JUROR QUESTIONNAIRES AND FOR PRE-QUALIFICATION OF JURORS

NOTICE OF HEARING 3.8.22 AT 9:00 AM (ZOOM) PLAINTIFF'S MOTION TO COMPEL:

MICHAEL MALTMAN’S SUPPLEMENTAL RESPONSE TO PLAINTIFF’S SUPPLEMENTAL REQUEST TO PRODUCE:

PLAINTIFF’SNOTICE OF TAKING DEPOSITION DUCES TECUM OF CLIFFORD TODD THOMPSON, M.D. ON 03.25.2022

MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP NOTICE OF FILING TRANSCRIPT OF DEPOSITION OF JOSEPH HILL:

PLAINTIFF’S 2ND AMENDED WITNESS LIST

DEFENDANTS’, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC, NOTICE OF JOINDER REGARDING DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC.’S MOTION TO STRIKE THE TESTIMONY OF PLAINTIFF'S EXPERT ECONOMIST, KRIS KUCSMA

PLAINTIFF’S 3RD AMENDED WITNESS LIST

PLAINTIFF’S RESPONSE TO EXPERT REQUEST TO PRODUCE OF MICHAEL MALTMAN, M.D.AND TREASURE COAST TOPDOC, PLLC:

PLAINTIFF'S EXPERT REQUEST TO PRODUCE TO ALL DEFENDANTS

DEFENDANT MICHAEL E. MALTMAN, M.D.’S WITNESS LIST:

NOTICE OF COMPLIANCE

PLAINTIFF’S MOTION FOR URGENT CASE MANAGEMENT CONFERENCE

PLAINTIFF’S NOTICE OF CANCELLATION OF VIDEOTAPED DEPOSITION DUCES TECUM:

PLAINTIFF’S NOTICE OF IMPEACHMENT MATERIAL

NOTICE TO PRODUCE COPIES OF DOCUMENTS:

PLAINTIFF’S NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM OF ALI RAJA, M.D. 3.30.22:

NOTICE OF PRODUCTION FROM NON PARTY

MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP NOTICE OF FILING TRANSCRIPT OF DEPOSITION OF CHELSEA HILL (ATTACHED)

CERTIFICATE OF NON-OBJECTION:

DEFENDANTS, MICHAEL MALTMAN, M.D.,AND TREASURE COAST TOPDOC, PLLC’S, MOTION TO COMPEL EXECUTED AUTHORIZATION:

DEFENDANTS, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S,EXHIBIT LIST

PLAINTIFF'S MOTION TO COMPEL

NOTICE OF SERVING ANSWERS TO INTERROGATORIES

DEFENDANTS,LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S AMENDED LIST OF EXPERT WITNESSES:

PLAINTIFF’S THIRD AMENDED EXHIBIT LIST:

PLAINTIFF’S FOURTH SUPPLEMENTAL REQUEST FOR PRODUCTION TO DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC.,D/B/A CLEVELAND CLINIC TRADITION HOSPITAL:

PLAINTIFF’S SUPPLEMENTAL REQUEST FOR PRODUCTION TO DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC.,D/B/A CLEVELAND CLINIC TRADITION HOSPITAL:

PLAINTIFF'S CERTIFICATE OF NO OBJECTION:

AMENDED NOTICE OF DESIGNATION OF TRIAL EXPERTS

NOTICE OF CANCELLATION OF HEARING 2.2.22 AT 9:00 AM RE: PLAINTIFF’S MOTION TO INSPECT ELECTRONIC CHART; AND PLAINTIFF’S MOTION TO COMPEL

PLAINTIFF’S NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM OF MICHAEL YAFFE, M.D. 3.30.22:

NOTICE OF CANCELLATION OF HEARING: FEBRUARY 2, 2022 AT 9:00 A.M. RE: DEFENDANT’S MOTION TO COMPEL BETTER RESPONSES TO REQUEST TO PRODUCE AND BETTER ANSWERS TO INTERROGATORIES

JOINT PRE-TRIAL STIPULATION:

REQUEST TO PRODUCE

PLAINTIFF’S NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM OF RAMONA LOUTOS ON 03.09.2022

DEFENDANTS,LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S LIST OF FACT WITNESSES

PLAINTIFF’S NOTICE OF SERVICE OF ANSWERS TO STATUTORY SURVIVOR INTERROGATORIES OF DEFENDANTS, MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, LLC:

DEFENDANTS LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S NOTICE OF TAKING REMOTE VIDEO CONFERENCE DEPOSITION DUCES TECUM VIA ZOOM OF PETER PAPPAS, M.D.:

PLAINTIFF’S AMENDED WITNESS LIST

MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP NOTICE OF FILING TRANSCRIPT OF DEPOSITION OF ROBERT HOLLOWAY, M.D. (ATTACHED)

PLAINTIFF’S SUPPLEMENTAL MATERIALS TO RESPONSE TO DEFENDANT’S MOTION IN LIMINE AS TO PRIOR CASES INVOLVING MS. KUCSMA –ECONOMIST:

ORDER ON DEFENDANT, MICHAEL MALTMAN, M.D.'S MOTION TO BE EXCUSED FROM A PORTION OF THE TRIAL DOCKET; TISIGNED 12.20.2021

PLAINTIFF’S MOTION TO INSPECT ELECTRONIC MEDICAL CHART OF DEFENDANT MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL:

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FINAL ORDER OF DISMISSAL WITH PREJUDICE AS TO DEFENDANTS LEONEL LOPEZ, D.O., AND PARAGON CONTRACTING SERVICES, LLC; SIGNED 07.06.2022 - RECORDED (RECORD DATE: 10/12/2022 8:53 AM / INSTRUMENT #: 2984503 BOOK#:3340 PAGE#: 1489)

FINAL ORDER OF DISMISSAL WITH PREJUDICE AS TO DEFENDANTS LEONEL LOPEZ, D.O., AND PARAGON CONTRACTING SERVICES, LLC; SIGNED 07.06.2022

JOINT STIPULATION FOR VOLUNTARY DISMISSAL WITH PREJUDICE AS TO LEONEL LOPEZ, D.O.AND PARAGON CONTRACTING SERVICES, LLC

STIPULATION FOR FINAL ORDER OF DISMISSAL WITH PREJUDICE

FINAL ORDER FOR DISMISSAL WITH PREJUDICE AS TO MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP; SIGNED 5.6.22:

STIPULATION FOR DISMISSAL WITH PREJUDICE AS TO MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A CLEVELAND CLINIC TRADITION HOSPITAL AND MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., D/B/A MARTIN HEALTH PHYSICIAN GROUP

NOTICE OF CANCELLATION OF DEPOSITION OF THEODORE WILLIAMS, PH.D 4.12.22:

NOTICE OF RESOLUTION

NOTICE OF WITHDRAWAL FOR CONSIDERATION THEIR MOTION TO DISMISS FOR FRAUD ON THE COURT OR IN THE ALTERNATIVE TO CONTINUE TRIAL

DEFENDANT, MICHAEL E. MALTMAN, M.D.,3RD AMENDED EXHIBIT LIST

LETTER TO JUDICIAL ASSISTANT FROM BONNIE NAVIN DATED 4.8.22:

DEFENDANT MICHAEL E. MALTMAN, M.D.’S SUPPLEMENTAL WITNESS LIST

SUBPOENA RETURNED SERVED UPON MICHAEL MALTMAN, M.D.

DEFENDANTS, MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, PLLC’S MOTION TO DISMISS FOR FRAUD ON THE COURT OR IN THE ALTERNATIVE TO CONTINUE TRIAL:

SUBPOENA RETURNED SERVED UPON RAMON LOUTOS

NOTICE OF TAKING DEPOSITION OF THEODORE WILLIAMS, PH.D ON 04.12.2022

DEFENDANTS, MARTIN MEMORIAL PHYSICIAN CORPORATION D/B/A MARTIN HEALTH PHYSICIAN GROUP AND MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, SECOND AMENDED EXHIBIT LIST

DEFENDANTS’, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC, NOTICE OF JOINDER REGARDING DEFENDANTS, MICHAEL MALTMAN, M.D. AND TREASURE COAST TOPDOC, PLLC’S MOTION TO DISMISS FOR FRAUD ON THE COURT OR IN THE ALTERNATIVE TO CONTINUE TRIAL

DEFENDANTS, MARTIN MEMORIAL PHYSICIAN CORPORATION D/B/A MARTIN HEALTH PHYSICIAN GROUP AND MARTIN MEMORIAL MEDICAL CENTER, INC. D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S, AMENDED FACT WITNESS LIST

DEFENDANT MARTIN MEMORIAL MEDICAL CENTER, INC.'S D/B/A CLEVELAND CLINIC TRADITION HOSPITAL'S REQUEST FOR COPIES TO CO-DEFENDANT, MICHAEL E. MALTMAN, M.D.

DEFENDANTS, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S RESPONSE TO PLAINTIFF’S NORTHRUP REQUEST TO PRODUCE

DEFENDANTS, LEONEL LOPEZ, D.O. AND PARAGON CONTRACTING SERVICES, LLC’S NOTICE OF SERVICE ANSWERS TO PLAINTIFF’S NORTHRUP INTERROGATORIES

SENIOR JUDGE ASSIGNMENT ORDER - SIGNED 12.22.21

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