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01-844
August 22, 2001
IN THE CIRCUIT COURT OF THE 20TH
JUDICIAL CIRCUIT IN AND FOR
ORIGINAL A" OTCoNT HONDA
CIVIL DIVISION
CASE NO. 00-120 CA
SALLY SIMON, as Personal Representative of the
Estate of MICHAEL SIMON,
Plaintiff, Charlotte County Clerk
1354710 Date : 08/24/01 - 15:19:22 o 008
Case#: 00000120CA ‘iil
cose esrc. cy. AMIFATN
Defendant.
/
DEFENDANT’S RESPONSE TO PLAINTIFF'S MOTIONS IN LIMINE
TO PRECLUDE THE USE OF DEPOSITION OF CHARLES VIRGIN, M.D. IN ITS
ENTIRETY AND TO PRECLUDE EVIDENCE OF NEGLIGENCE AS TO MAURICIO
CASTELLON, M.D. VIA THE DEPOSITION OF CHARLES VIRGIN, M.D.
Defendant, SAMUEL ESTEPA, M.D., responds to "Plaintiffs Motion In Limine To
Preclude The Use of Deposition Of Charles Virgin, M.D., In Its Entirety" and to “Plaintiff's
Motion In Limine To Preclude Evidence Of Negligence As To Mauricio Castellon, M.D. Via
The Deposition Of Charles Virgin, M.D.," and respectfully requests that this Court deny said
motions, and as grounds therefore states:
1, Pla…
