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DAK:ik IN THE CIRCUIT COURT OF THE
97-605 20" JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
CASE NO. 00-120 CA
SALLY SIMON, as Personal
Representative of the Estate of
Michael Simon,
Plaintiff,
vs.
@2stinY 12 an¥ lane
aid
Ch
SAMUEL ESTEPA,M.D., 64359747 Date » OB2I08 14 on2s is im
Case#: 00000120CA Pages
cee THMTULT ACT”
PLAINTIFF’S MOTION IN LIMINE TO PRECLUDE THE USE OF
DEPOSITION OF CHARLES VIRGIN, M_D., IN ITS ENTIRETY
COMES NOW, the Plaintiff, SALLY SIMON, as Personal Representative of the
Estate of Michael Simon, by and through her undersigned attorney, and hereby moves
this Court in limine to prevent Defendant, SAMUEL ESTEPA, M.D., from using the
deposition of Charles Virgin, M.D., in its entirety. In support of said Motion, Plaintiff
states:
1. Dr. Charles Virgin was listed by the Plaintiff as her expert physician on
the issue of violation of the standard of care by former Defendant, orthopedist DR.
DALE GREENBERG, M.D.
2. In Nash v. Wells Fargo Guard…
