Party Discovery: SIMON SALLY vs. ASPERILLA MARK MD

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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. 00-120CA

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

GREENBERG, M.D., RONALD
CONSTINE, M.D., LEVY BAKER
CONSTINE & GREENBERG, M.D.

P.A., a Florida corporation, SAMUEL
ESTEPA, M.D., PRIMARY CARE
PHYSICIANS, INC., a Florida corpora-
tion, NASIR KHALIDI, M.D., NASIR
KHALIDI, M.D., & 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 crests Date : 12/42/00 - 14:13:30 id: 14

e#: 00000120CA mil 0004

RADIOLOGY GROUP, and BON SECOURS-
eserarseraceteccoesin THAN NUE

Defendants.

da

Stuy py 930 8003

Charlotte County Clerk

/

RESPONSE TO REQUEST TO PRODUCE OF
DEFENDANT, BON SECOURS-ST. JOSEPH HEALTHCARE GROUP,
alk/a BON SECOURS-ST. JOSEPH HOSPITAL

KOLTUN & LAZAR, P.A., ATTORNEYS AT LAW, 7101 S.W. 102"? AVENUE, MIAMI, FL 33173 (305) 595-6791

IMAGED
LMSimon v. Asperilla, M.D., etal., Case No. 00-120-CA

COMES NOW, the Plaintiff, SALLY SIMON, as Personal Representative of the
Estate of Michael Simon, by and through her undersigned attorney, and in response to the
Request To Produce propounded to said party by Defendant, BON-SECOURS-ST.
JOSEPH HEALTHCARE GROUP, INC. a/k/a BON SECOURS-ST. JOSEPH HOSPITAL.,
on October 13, 2000, states as follows:

1. Response to Request No. 1, attached are copies of individuai tax returns re
Michael Simon and Sarah (Sally) Simon for period: 1996-1998; income tax returns, Jolly
Roger Boat Rental, Inc. for period: 1986-1993; and income tax returns, Home Port Marine
Services, Inc., for period: 1989-1997.

2. Response to Request No. 2, none.

3. Response to Request No. 3, medical records are voluminous. Plaintiff will
be happy to photocopy said records provided that they are reimbursed the cost of
photocopying and clerical fees.

4. Request to Request No. 4, Plaintiffis not in possession of the originals of any
films, MRI's and/or CT scans taken of Michael Simon, deceased.

5. Response to Request No. 5, none in Plaintiffs possession.

6. Response to Request No. 6, attached are copies of any and all medical
records, etc. in Plaintiff's possession as to Michael Simon, deceased, during the ten year
period prior to his death.

7. Response to Request No. 7, none.

8. Response to Request No. 8, see response to No. 3 above.

KOLTUN & LAZAR, P.A., ATTORNEYS AT LAW, 7101 S.W. 102"° AVENUE, MIAMI, FL 33173 (305) 595-67919.

Simon v. Asperilla, M.D., etal., Case No. 00-120-CA

Response to Request No. 9, documentation from Public Consulting Group,

Inc. as to subrogation lien of Medicaid is attached. Copies of funeral home and cemetery

bills also attached.

10.
11.
12.
13.
14,
15.

Response to Request No. 10, none.
Response to Request No. 11, none.
Response to Request No. 12, none.
Response to Request No. 13, none.
Response to Request No. 14, to be furnished as soon as received.

Response to Request No.15, photographs in Plaintiffs possession are

available for inspection at a mutually convenient date and time.

16.
17.
18.
19.
20.
21.
22.
23.

Response to Request No. 16, undetermined at this time.
Response to Request No. 17, attached.

Response to Request No. 18, copy of Will of decedent attached.
Response to Request No. 19, attached.

Response to Request No. 20, objection - work product.
Response to Request No. 21, none.

Response to Request No. 22, see Response to No. 1 above.

Response to Request No. 23, see Response to No. 1 above.

| HEREBY CERTIFY that a true and correct copy of the foregoing, together with

copies of requested documentation, were mailed this oe day of Retdes,, 2000 to:

KELLY JO SCHMEDT, ESQ., Hahn, Morgan & Lamb, P.A., Attorneys for Defendant, Bon-

Secours-St. Joseph Hospital, 2701 N. Rocky Point Drive, #410, Tampa, FL 33607-5917;

KOLTUN & LAZAR, P.A., ATTORNEYS AT LAW, 7101 S.W. 102"° AVENUE, MIAMI, FL 33173 (305) 595-6791Simon v. Asperilla, M.D., etal., Case No. 00-120-CA
and true and correct copies of the foregoing Response were furnished to all counsel listed
on attached certificate of service.

KOLTUN & LAZAR, P.A.
Attorneys for Plaintiff

7101 S.W. 102 Avenue
Miami, FL 33173

305 595-6791 - Dade
305 595-5400 - Fascimile

DENNIS A. KOLTUN
Fla. Bar No. 163040

KOLTUN & LAZAR, P.A., ATTORNEYS AT LAW, 7101 S.W. 102° AVENUE, MIAMI, FL 33173 (305) 595-6791