Document for HILL, AS PERSONAL REPRESENTATIVE OF THE ESTATE OF MARGARET CARLTON DECEASED, CHELSEA vs. LOPEZ, LEONEL D.O.

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                                Filing # 145338458 E-Filed 03/09/2022 08:40:09 AM

                IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT IN AND FOR
                                 MARTIN COUNTY, FLORIDA
                                     CASE NO. 21-610-CA

        CHELSEA HILL, as Personal Representative of
        the Estate of Margaret Carlton, deceased,

               Plaintiff,
        v.

        LEONEL LOPEZ, D.O.; PARAGON CONTRACTING SERVICE, LLC;
        MICHAEL MALTMAN, M.D.; TREASURE COAST TOPDOC, PLLC;
        MARTIN MEMORIAL MEDICAL CENTER, INC., d/b/a CLEVELAND
        CLINIC TRADITION HOSPITAL; and MARTIN MEMORIAL PHYSICIAN
        CORPORATION, INC., d/b/a MARTIN HEALTH PHYSICIAN GROUP,

              Defendants.
        ______________________________________________________/

         PLAINTIFF’S RESPONSE TO SECOND SUPPLEMENTAL REQUEST TO PRODUCE
                        OF MARTIN MEMORIAL MEDICAL CENTER

               Plaintiff, CHELSEA HILL. As Personal Representative of the Estate of Margaret
        Carlton, by and through her undersigned counsel, hereby files her response to Defendant’s
        Second Supplemental Request for Production served February 28, 2022, as follows:


               1.      An executed Authorization for Release of Protected Health Information from

        Vitas Hospice (form attached.)

                       Attached.

               2.      An executed Authorization for Release of Protected Health Information from

        Treasure Coast Hospice (form attached).

                       Attached.

               3.      An executed Authorization for Release of Protected Health Information from Fort

        Pierce VA Clinic (form attached).

                       Attached.
       4.     An executed Authorization for Release of Protected Health Information from the

VA Clinic Lakeland (form attached).

              Attached.

       5.     An executed Authorization for Release of Protected Health Information from

West Palm Beach VA Clinic (form attached).

              Attached.


                               CERTIFICATE OF SERVICE

         SWE HEREBY CERTIFY a copy of the foregoing was filed with the Eportal who will
serve copies of same on: sent by electronic mail to Thomas Aubin, Esq., Stearns Weaver, et al.,
200 E. Las Olas Blvd., Suite 2100, Ft. Lauderdale, FL 33301, mpodolnick@stearnsweaver.com;
taubin@stearnsweaver.com; aspencer@stearnsweaver.com), James White, Esq, White &
Russell, P.A., 11641 Kew Gardens Avenue, Suite 101, Palm Beach Gardens, FL 33410.,
(white@wrtrial.com;      walsh@wrtrial.com;        leone@wrtrial.com;     parker@wrtrial.com;
wanser@wrtrial.com; pleadings@wrtrial.com) and Robert Paradela, Esq., Wicker Smith, et al.,
515      E.    Las  Olas     Blvd.,    Suite    1400,    Ft.   Lauderdale,    FL       33301
                                         th
(ftlcrtpleadings@wickersmith.com) this 9 day of March, 2022.

                                                   RUBENSTEIN LAW, P.A.
                                                   Attorneys for Plaintiff
                                                   9130 S. Dadeland Blvd., PH
                                                   Miami, FL 33156
                                                   Tel.: 305/661-6000
                                                   Fax: 786/230-2934
                                                   Email:bonnie@rubensteinlaw.com
                                                          efabricant@rubensteinlaw.com
                                                          eservice@rubensteinlaw.com


                                                          By: /s/ Bonnie Navin
                                                          Bonnie Navin, Esquire
                                                          Fla Bar No. 48775