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IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. 00-t544 CA
1a0-CA
SALLY SIMON, as Personal Representative
of the Estate of Michael Simon, Charlotte County Clerk
1281005 Date : 04/13/04 - 10:57:45 id: 54
Plaintiff, Case#: 00000120CA Hill 0004
ws CACC
oy
CONRAD EPPING KOERPER, M_D.,
COLEMAN & CASTELLON, M_D., P.A.,
a/k/a CHARLOTTE RADIOLOGY GROUP,
and BON SECOURS - ST. JOSEPH
HEALTH CARE GROUP, INC., a/k/a
BON SECOURS - ST. JOSEPH HOSPITAL,
a Florida corporation,
Defendants.
/
EMERGENCY MOTION FOR PROTECTIVE ORDER
COMES NOW the Defendant, CONRAD EPPING KOERPER, M.D., by and through his
undersigned counsel, and moves this Honorable Court for a Protective Order regarding the
deposition of REED F. MURTAGH, M.D., presently set for April 10, 2001 at 2:00 p.m., and as
grounds therefor would state as follows:
1. Plaintiff's counsel, Thomas A. Culmo, Esq., has set the deposition of Reed F.
Murtagh, M.D., for…
