Preview
Charlotte County Clerk
01264156 Date : 03/13/01 - 14:57:56 id: 14
BARBARA T. SCOTT 2
CLERK OF THE CIRCUIT COURT . %
«
92)
CIRCUIT COURT * COUNTY COURT * COUNTY RECORDER ¢ CLERK BOARD OF COUNTY COMMISSIONERS
TO:
Culmo & Culmo, PA REPLY TO: CIVIL DIVISION
2400 S Dixie Highway Ste 100 DATE:;__ 3713-01
Miami, FL 33133 CASE NO: 00-120-CA
PLEASE BE ADVISED OF THE FOLLOWING:
ges: 0008
IANO
|
Case#: 00000120CA Pa
The correct file number pursuant to 1.100(c) has not been provided. Please provide the
correct case number and return to this office.
Your notice for trial has been received by our office, however, we cannot submit your
notice to the Court as it does not comply with Rule 1.440(b), Florida Rules of Civil
Procedure. Please provide this office with an amended notice for trial so that we may
advise the Court.
Your case is being returned due to incorrect filing fee. Upon receipt of the correct filing
fee in the amount of $ this office shall file this case.
Please be advised that a motion for default has been filed with the Clerk of the Court in
the above-styled cause. The records of this office reflect that a paper was filed on
, accordingly, the default has not been entered.
Pursuant to Rule 2.055 of the Florida Rules of Judicial Administration, all pleadings filed
in court after January 1, 1991 shall be on paper measuring 81/2 X 11 inches.
Default denied - No proof of service or publication.
Vital Statistics form needed.
= ne
. 2s sS
Per our telephone conversation on 3-9-01, we need the
the attached forms in order to file them. I have not heard "backs
from you.
Should you have any questions, please do not hesitate to contact this office afi) 635 ea. afi
Civil Court, or (941) 637-2119 County Court. a5. ~ cl
ago ow
ov
BARBARA T. SCOTT
CLERK OF a cIRCcUIT CouRT IMAGED -
By:
vans
ctnsgd
Deputy Clerk P.O. Box 511687 @ Punta Gorda @ Florida @ 33951-1687
Punta Gorda 941-505-4716 @ Murdock 941-743-1400 @ Englewood 941-474-1220IN THE CIRCUIT COURT OF THE 20™
JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO: 00-120 CA
SALLY SIMON, as Personal Representative
of the Estate of MICHAEL SIMON,
Plaintiff,
vs.
MARK ASPERILLA, M.D., MARK ASPERILLA,
MLD., P.A., a Florida Corporation, DALE GREEN-
BERG, M.D., RONALD CONSTINE, M.D., LEVY,
BAKER, CONSTINE & GREENBERG, MLD., P.A.,
a Florida Corporation, SAMUEL ESTEPA, M_D.,
NASIR KHALIDI, M.D., NASIR KHALIDI & SAKINA
KHALIDI, M.D., P.A., a Florida Corporation, and
CONRAD EPPING KOERPER, M.D., COLEMAN &
CASTELLON, M.D., P.A., a/k/a CHARLOTTE
RADIOLOGY GROUP and BON SECOURS-ST.
JOSEPH HOSPITAL, a Florida Coporation,
Defendants.
/
PLAINTIFF’S RESPONSE TO DEFENDANT ESTEPA’S MOTION
FOR PROTECTIVE ORDER/OBJECTIONS TO INTERROGATORIES
DATED JANUARY 30, 2001 AND MOTION TO COMPEL AND FOR SANCTIONS
COMES NOW, the Plaintiff SALLY SIMON, as Personal Representative of the Estate of
MICHAEL SIMON, by and through undersigned counsel and files this response to Defendant,
Samuel Estepa, M.D.’s Motion for Protective Order dated February 26, 2001 and states as
follows:
1. Plaintiff, to date, has filed four very limited and very specific sets of interrogatories
to Defendant Estepa.
2. The Plaintiff's first set of interrogatories were filed on May 9, 2000 and contained
CULMO & CULMO, P.A., 2400 SOUTH DIXIE HIGHWAY, SUITE 100, MIAMI, FL 33133 + (308) 856-4004four specific interrogatories seeking information regarding Defendant Estepa’s
claims, and whether any other parties or entities were responsible for, or at fault in
causing, the injuries or damages about which Plaintiff complained.
3. Plaintiff's second set of interrogatories filed on May 23, 2000 included three
interrogatories that were intended for clarifying portions of Defendant Estepa’s
written entries in the hospital medical chart.
4. Plaintiff's third set of interrogatories were filed on August 29, 2000 and sought the
identity of any expert witnesses Defendant Estepa intended to call at the time of trial.
Defendant Estepa answered these “undetermined at present” thereby not disclosing
any of its intended trial experts.
5. The total number of these three sets of interrogatories, including subparts, was 24.
6. Florida Rules of Civil Procedure, Rule 1.340(a) allows a party without leave of court
to serve interrogatories upon any other party. Leave of court is not required unless
the interrogatories exceed 30, including all subparts.
7. The interrogatories at issue, which have prompted Defendant Estepa’s objections and
motion for protective order, were filed on January 30, 2001 and contain three specific
questions. Since Plaintiffhas still not reached 30 interrogatories (including the most
recent set), leave of court is not required. ,
8. Defendant Estepa’s motion refers to the fact that Defendant’s deposition has been
taken and five sets of requests for admissions have been filed by Plaintiff to
Defendant Estepa. As the court knows, this is a multi-defendant case. Dr. Estepa
was the first Defendant deposed. Since his deposition, factual questions and issues
have arisen following the depos of other party Defendants and other witnesses which
require Plaintiff to employ the rules and tools of discovery permitted under the
CULMO & CULMO, P.A., 2400 SOUTH DIXIE HIGHWAY, SUITE 100, MIAMI, FL 33133 + (305) 856-4004Florida Rules of Civil Procedure.
9. Plaintiff had every right under the Florida Rules of Civil Procedure to file its
interrogatories dated January 30, 2001, and did so in a good faith effort to clarify and
narrow the issues in this matter and to advance its claims.
10. On the contrary, Defendant's objections are not only legally without merit but are
contrary to the Florida Rules.
WHEREFORE, Plaintiff respectfully moves that Defendant Estepa’s motion for protective
order be denied, his objections overruled and that he be compelled to answer the subject
interrogatories forthwith. Plaintiff would also respectfully move that sanctions be imposed against
Defendant Estepa, including but not limited to attorney's fees and costs for having to defend this
motion and these objections as they are without merit and not based on any legal authority.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served by mail
on: ALL COUNSEL OF RECORD on this 6" day of March, 2001.
CULMO & CULMO, P.A.
Attorneys for the Plaintiff
2400 South Dixie Highway
~ Suite 100
Miami, Florida 33133
Phone: (305) 856-4004
Fax: (305) 854-5445
olin bude (6)
Thomas A. Culmo
Florida Bar: 775479
F.ACASES\SIMON\PLEADING\ESTEPAresp. wpd
CULMO & CULMO, P.A., 2400 SOUTH DIXIE HIGHWAY, SUITE 100, MIAMI, FL 33133 + (305) 686-4004SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Deceased
CERTIF F VICE
A. Lynn H. Groseciose, Esq. 6. RAYMOND A. REISER, ESQ.
Attorney for Asperilla Attorney for Conrad Koerper
PO Box 730 Reiser & Allison
Bradenton, Florida 34206 1 SE 3" Avenue, Suite 1860
Phone: 941-741-8300 Miami, Florida 33131-1704
Fax: 941-741-8355 Phone: 305-379-5316
Fax: 305-379-6917
2. Craig Stevens, Esq. 7. BENITO DIAZ, ESQUIRE
Attorney for Constine, Greenberg & Levy Attorney for Samuel Estepa
George, Hartz, Lundeen & Fulmer Diaz & Morel-Saruski
2000 Main Street, Suite 402 2912 Douglas Road
Ft. Myers, Florida 33901 Coral Gables, FL 33134
Phone: 941-337-7787 Phone: 305-529-9910 Ext. 12
Fax: 941-337-4303 Fax: 305-529-9913
3. John Hamilton, Esq.
Attorney for Dr. Khalidi 8. CLIFFORD L. SOMERS, ESQ.
100 North Tampa Street Attorneys for Coleman & Castellon
Suite 3650 Barr, Murman & Tonelli, P.A.
Tampa, Florida 33602 201 East Kennedy Blvd., #1750
Phone: 813-222-3939 Tampa, FL 33602
Fax: 813-222-3938 Telephone : 813-223-3951
Fax: 813-229-2254 or
4. DENNIS KOLTUN, ESQUIRE Fax: 813-209-0214
Co-counsel for Sally Simon
7000 S.W. 97" Avenue
Suite 210
Miami, Florida 33173
Phone: 305-595-6791
Fax: 305-595-5400
5. EUGENE H. SMITH, ESQ.
Attorneys for Bon Secours-St. Joseph
Henderson Franklin
1715 Monroe Street
Fort Myers, Florida 33901-3072
Phone: 941-334-4121
Fax: 941-334-4100IN THE CIRCUIT COURT OF THE 20™
JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO: 00-120 CA
SALLY SIMON, as Personal Representative
of the Estate of MICHAEL SIMON,
Plaintiff,
VS.
MARK ASPERILLA, M.D., MARK ASPERILLA,
M.D., P.A., a Florida Corporation, DALE GREEN-
BERG, M.D., RONALD CONSTINE, M.D., LEVY,
BAKER, CONSTINE & GREENBERG, M_D., P.A.,
a Florida Corporation, SAMUEL ESTEPA, M_D.,
NASIR KHALIDI, M.D., NASIR KHALIDI & SAKINA
KHALIDI, M.D., P.A., a Florida Corporation, and
CONRAD EPPING KOERPER, M.D., COLEMAN &
CASTELLON, M.D., P.A., a/k/a CHARLOTTE
RADIOLOGY GROUP and BON SECOURS-ST.
JOSEPH HOSPITAL, a Florida Coporation,
Defendants.
/
REPLY
The Plaintiff, SALLY SIMON, as Personal Representative of the Estate of Michael Simon,
by and through undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, files this
Reply to Samuel Estepa’s Amended Answer, Affirmative Defenses, and Request for Jury Trial dated
March 2, 2001 to Plaintiff's Amended Complaint and states as follows:
1. That the Plaintiffs deny each and every affirmative defense set forth in Defendant’s
Samuel Estepa’s Amended Answer, Affirmative Defenses, and Request for Jury Trial
and demand strict proof thereof.
CULMO & CULMO, P.A., 2400 SOUTH OIXIE HIGHWAY, SUITE (00, MIAMI, FL 33133 + (308) 856-4004CE A ERVI
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served to ALL
ye
COUNSEL OF RECORD via U.S. Mail on this l g__ day of March, 2001.
CULMO & CULMO, P.A.
Attorneys for the Plaintiffs
2400 South Dixie Highway, Suite 100
Miami, Florida 33133
Telephone (305) 856-4004
Telefax (305) 854-5445
-2-
CULMO & CULMO, P.A., 2400 SOUTH DIXIE HIGHWAY, SUITE 100, MIAMI, FL: 33133 + (308) 856-4004SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Deceased
CERTIFICATE OF SERVICE
1. Lynn H. Groseclose, Esq. 6. RAYMOND A. REISER, ESQ.
Attorney for Asperilla Attorney for Conrad Koerper
PO Box 730 Reiser & Allison
Bradenton, Florida 34206 1 SE 3" Avenue, Suite 1860
Phone: 941-741-8300 Miami, Florida 33131-1704
Fax: 941-741-8355 Phone: 305-379-5316
Fax: 305-379-6917
2. Craig Stevens, Esq. 7. BENITO DIAZ, ESQUIRE
Attorney for Constine, Greenberg & Levy Attorney for Samuel Estepa
George, Hartz, Lundeen & Fulmer Diaz & Morel-Saruski
2000 Main Street, Suite 402 2912 Douglas Road
Ft. Myers, Florida 33901 Coral Gables, FL 33134
Phone: 941-337-7787 Phone: 305-529-9910 Ext. 12
Fax: 941-337-4303... Fax: 305-529-9913
3. John Hamilton, Esq.
Attorney for Dr. Khalidi 8. CLIFFORD L. SOMERS, ESQ.
100 North Tampa Street Attorneys for Coleman & Castellon
Suite 3650 Barr, Murman & Tonelli, P.A.
Tampa, Florida 33602 201 East Kennedy Blvd., #1750
Phone: 813-222-3939 Tampa, FL 33602
Fax: 813-222-3938 Telephone : 813-223-3951
Fax: 813-229-2254 or
4. DENNIS KOLTUN, ESQUIRE Fax: 813-209-0214
Co-counsel for Sally Simon
7000 S.W. 97" Avenue
Suite 210
Miami, Florida 33173 .
Phone: 305-595-6791 os
Fax: 305-595-5400
5. EUGENE H. SMITH, ESQ.
Attorneys for Bon Secours-St. Joseph
Henderson Franklin
1715 Monroe Street
Fort Myers, Florida 33901-3072
Phone: 941-334-4121
Fax: 941-334-4100
Preview
Charlotte County Clerk 01264156 Date : 03/13/01 - 14:57:56 id: 14 BARBARA T. SCOTT 2 CLERK OF THE CIRCUIT COURT . % « 92) CIRCUIT COURT * COUNTY COURT * COUNTY RECORDER ¢ CLERK BOARD OF COUNTY COMMISSIONERS TO: Culmo & Culmo, PA REPLY TO: CIVIL DIVISION 2400 S Dixie Highway Ste 100 DATE:;__ 3713-01 Miami, FL 33133 CASE NO: 00-120-CA PLEASE BE ADVISED OF THE FOLLOWING: ges: 0008 IANO | Case#: 00000120CA Pa The correct file number pursuant to 1.100(c) has not been provided. Please provide the correct case number and return to this office. Your notice for trial has been received by our office, however, we cannot submit your notice to the Court as it does not comply with Rule 1.440(b), Florida Rules of Civil Procedure. Please provide this office with an amended notice for trial so that we may advise the Court. Your case is being returned due to incorrect filing fee. Upon receipt of the correct filing fee in the amount of $ this office shall file this case. Please be advised that a motion for default has been filed with the Clerk of the Court in the above-styled cause. The records of this office reflect that a paper was filed on , accordingly, the default has not been entered. Pursuant to Rule 2.055 of the Florida Rules of Judicial Administration, all pleadings filed in court after January 1, 1991 shall be on paper measuring 81/2 X 11 inches. Default denied - No proof of service or publication. Vital Statistics form needed. = ne . 2s sS Per our telephone conversation on 3-9-01, we need the the attached forms in order to file them. I have not heard "backs from you. Should you have any questions, please do not hesitate to contact this office afi) 635 ea. afi Civil Court, or (941) 637-2119 County Court. a5. ~ cl ago ow ov BARBARA T. SCOTT CLERK OF a cIRCcUIT CouRT IMAGED - By: vans ctnsgd Deputy Clerk P.O. Box 511687 @ Punta Gorda @ Florida @ 33951-1687 Punta Gorda 941-505-4716 @ Murdock 941-743-1400 @ Englewood 941-474-1220IN THE CIRCUIT COURT OF THE 20™ JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO: 00-120 CA SALLY SIMON, as Personal Representative of the Estate of MICHAEL SIMON, Plaintiff, vs. MARK ASPERILLA, M.D., MARK ASPERILLA, MLD., P.A., a Florida Corporation, DALE GREEN- BERG, M.D., RONALD CONSTINE, M.D., LEVY, BAKER, CONSTINE & GREENBERG, MLD., P.A., a Florida Corporation, SAMUEL ESTEPA, M_D., NASIR KHALIDI, M.D., NASIR KHALIDI & SAKINA KHALIDI, M.D., P.A., a Florida Corporation, and CONRAD EPPING KOERPER, M.D., COLEMAN & CASTELLON, M.D., P.A., a/k/a CHARLOTTE RADIOLOGY GROUP and BON SECOURS-ST. JOSEPH HOSPITAL, a Florida Coporation, Defendants. / PLAINTIFF’S RESPONSE TO DEFENDANT ESTEPA’S MOTION FOR PROTECTIVE ORDER/OBJECTIONS TO INTERROGATORIES DATED JANUARY 30, 2001 AND MOTION TO COMPEL AND FOR SANCTIONS COMES NOW, the Plaintiff SALLY SIMON, as Personal Representative of the Estate of MICHAEL SIMON, by and through undersigned counsel and files this response to Defendant, Samuel Estepa, M.D.’s Motion for Protective Order dated February 26, 2001 and states as follows: 1. Plaintiff, to date, has filed four very limited and very specific sets of interrogatories to Defendant Estepa. 2. The Plaintiff's first set of interrogatories were filed on May 9, 2000 and contained CULMO & CULMO, P.A., 2400 SOUTH DIXIE HIGHWAY, SUITE 100, MIAMI, FL 33133 + (308) 856-4004four specific interrogatories seeking information regarding Defendant Estepa’s claims, and whether any other parties or entities were responsible for, or at fault in causing, the injuries or damages about which Plaintiff complained. 3. Plaintiff's second set of interrogatories filed on May 23, 2000 included three interrogatories that were intended for clarifying portions of Defendant Estepa’s written entries in the hospital medical chart. 4. Plaintiff's third set of interrogatories were filed on August 29, 2000 and sought the identity of any expert witnesses Defendant Estepa intended to call at the time of trial. Defendant Estepa answered these “undetermined at present” thereby not disclosing any of its intended trial experts. 5. The total number of these three sets of interrogatories, including subparts, was 24. 6. Florida Rules of Civil Procedure, Rule 1.340(a) allows a party without leave of court to serve interrogatories upon any other party. Leave of court is not required unless the interrogatories exceed 30, including all subparts. 7. The interrogatories at issue, which have prompted Defendant Estepa’s objections and motion for protective order, were filed on January 30, 2001 and contain three specific questions. Since Plaintiffhas still not reached 30 interrogatories (including the most recent set), leave of court is not required. , 8. Defendant Estepa’s motion refers to the fact that Defendant’s deposition has been taken and five sets of requests for admissions have been filed by Plaintiff to Defendant Estepa. As the court knows, this is a multi-defendant case. Dr. Estepa was the first Defendant deposed. Since his deposition, factual questions and issues have arisen following the depos of other party Defendants and other witnesses which require Plaintiff to employ the rules and tools of discovery permitted under the CULMO & CULMO, P.A., 2400 SOUTH DIXIE HIGHWAY, SUITE 100, MIAMI, FL 33133 + (305) 856-4004Florida Rules of Civil Procedure. 9. Plaintiff had every right under the Florida Rules of Civil Procedure to file its interrogatories dated January 30, 2001, and did so in a good faith effort to clarify and narrow the issues in this matter and to advance its claims. 10. On the contrary, Defendant's objections are not only legally without merit but are contrary to the Florida Rules. WHEREFORE, Plaintiff respectfully moves that Defendant Estepa’s motion for protective order be denied, his objections overruled and that he be compelled to answer the subject interrogatories forthwith. Plaintiff would also respectfully move that sanctions be imposed against Defendant Estepa, including but not limited to attorney's fees and costs for having to defend this motion and these objections as they are without merit and not based on any legal authority. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served by mail on: ALL COUNSEL OF RECORD on this 6" day of March, 2001. CULMO & CULMO, P.A. Attorneys for the Plaintiff 2400 South Dixie Highway ~ Suite 100 Miami, Florida 33133 Phone: (305) 856-4004 Fax: (305) 854-5445 olin bude (6) Thomas A. Culmo Florida Bar: 775479 F.ACASES\SIMON\PLEADING\ESTEPAresp. wpd CULMO & CULMO, P.A., 2400 SOUTH DIXIE HIGHWAY, SUITE 100, MIAMI, FL 33133 + (305) 686-4004SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Deceased CERTIF F VICE A. Lynn H. Groseciose, Esq. 6. RAYMOND A. REISER, ESQ. Attorney for Asperilla Attorney for Conrad Koerper PO Box 730 Reiser & Allison Bradenton, Florida 34206 1 SE 3" Avenue, Suite 1860 Phone: 941-741-8300 Miami, Florida 33131-1704 Fax: 941-741-8355 Phone: 305-379-5316 Fax: 305-379-6917 2. Craig Stevens, Esq. 7. BENITO DIAZ, ESQUIRE Attorney for Constine, Greenberg & Levy Attorney for Samuel Estepa George, Hartz, Lundeen & Fulmer Diaz & Morel-Saruski 2000 Main Street, Suite 402 2912 Douglas Road Ft. Myers, Florida 33901 Coral Gables, FL 33134 Phone: 941-337-7787 Phone: 305-529-9910 Ext. 12 Fax: 941-337-4303 Fax: 305-529-9913 3. John Hamilton, Esq. Attorney for Dr. Khalidi 8. CLIFFORD L. SOMERS, ESQ. 100 North Tampa Street Attorneys for Coleman & Castellon Suite 3650 Barr, Murman & Tonelli, P.A. Tampa, Florida 33602 201 East Kennedy Blvd., #1750 Phone: 813-222-3939 Tampa, FL 33602 Fax: 813-222-3938 Telephone : 813-223-3951 Fax: 813-229-2254 or 4. DENNIS KOLTUN, ESQUIRE Fax: 813-209-0214 Co-counsel for Sally Simon 7000 S.W. 97" Avenue Suite 210 Miami, Florida 33173 Phone: 305-595-6791 Fax: 305-595-5400 5. EUGENE H. SMITH, ESQ. Attorneys for Bon Secours-St. Joseph Henderson Franklin 1715 Monroe Street Fort Myers, Florida 33901-3072 Phone: 941-334-4121 Fax: 941-334-4100IN THE CIRCUIT COURT OF THE 20™ JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO: 00-120 CA SALLY SIMON, as Personal Representative of the Estate of MICHAEL SIMON, Plaintiff, VS. MARK ASPERILLA, M.D., MARK ASPERILLA, M.D., P.A., a Florida Corporation, DALE GREEN- BERG, M.D., RONALD CONSTINE, M.D., LEVY, BAKER, CONSTINE & GREENBERG, M_D., P.A., a Florida Corporation, SAMUEL ESTEPA, M_D., NASIR KHALIDI, M.D., NASIR KHALIDI & SAKINA KHALIDI, M.D., P.A., a Florida Corporation, and CONRAD EPPING KOERPER, M.D., COLEMAN & CASTELLON, M.D., P.A., a/k/a CHARLOTTE RADIOLOGY GROUP and BON SECOURS-ST. JOSEPH HOSPITAL, a Florida Coporation, Defendants. / REPLY The Plaintiff, SALLY SIMON, as Personal Representative of the Estate of Michael Simon, by and through undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, files this Reply to Samuel Estepa’s Amended Answer, Affirmative Defenses, and Request for Jury Trial dated March 2, 2001 to Plaintiff's Amended Complaint and states as follows: 1. That the Plaintiffs deny each and every affirmative defense set forth in Defendant’s Samuel Estepa’s Amended Answer, Affirmative Defenses, and Request for Jury Trial and demand strict proof thereof. CULMO & CULMO, P.A., 2400 SOUTH OIXIE HIGHWAY, SUITE (00, MIAMI, FL 33133 + (308) 856-4004CE A ERVI WE HEREBY CERTIFY that a true and correct copy of the foregoing was served to ALL ye COUNSEL OF RECORD via U.S. Mail on this l g__ day of March, 2001. CULMO & CULMO, P.A. Attorneys for the Plaintiffs 2400 South Dixie Highway, Suite 100 Miami, Florida 33133 Telephone (305) 856-4004 Telefax (305) 854-5445 -2- CULMO & CULMO, P.A., 2400 SOUTH DIXIE HIGHWAY, SUITE 100, MIAMI, FL: 33133 + (308) 856-4004SALLY SIMON, as Personal Representative of the Estate of Michael Simon, Deceased CERTIFICATE OF SERVICE 1. Lynn H. Groseclose, Esq. 6. RAYMOND A. REISER, ESQ. Attorney for Asperilla Attorney for Conrad Koerper PO Box 730 Reiser & Allison Bradenton, Florida 34206 1 SE 3" Avenue, Suite 1860 Phone: 941-741-8300 Miami, Florida 33131-1704 Fax: 941-741-8355 Phone: 305-379-5316 Fax: 305-379-6917 2. Craig Stevens, Esq. 7. BENITO DIAZ, ESQUIRE Attorney for Constine, Greenberg & Levy Attorney for Samuel Estepa George, Hartz, Lundeen & Fulmer Diaz & Morel-Saruski 2000 Main Street, Suite 402 2912 Douglas Road Ft. Myers, Florida 33901 Coral Gables, FL 33134 Phone: 941-337-7787 Phone: 305-529-9910 Ext. 12 Fax: 941-337-4303... Fax: 305-529-9913 3. John Hamilton, Esq. Attorney for Dr. Khalidi 8. CLIFFORD L. SOMERS, ESQ. 100 North Tampa Street Attorneys for Coleman & Castellon Suite 3650 Barr, Murman & Tonelli, P.A. Tampa, Florida 33602 201 East Kennedy Blvd., #1750 Phone: 813-222-3939 Tampa, FL 33602 Fax: 813-222-3938 Telephone : 813-223-3951 Fax: 813-229-2254 or 4. DENNIS KOLTUN, ESQUIRE Fax: 813-209-0214 Co-counsel for Sally Simon 7000 S.W. 97" Avenue Suite 210 Miami, Florida 33173 . Phone: 305-595-6791 os Fax: 305-595-5400 5. EUGENE H. SMITH, ESQ. Attorneys for Bon Secours-St. Joseph Henderson Franklin 1715 Monroe Street Fort Myers, Florida 33901-3072 Phone: 941-334-4121 Fax: 941-334-4100