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Filing # 140518509 E-Filed 12/16/2021 01:53:02 PM
IN THE CIRCUIT COURT OF THE
19" JUDICIAL CIRCUIT IN AND
FOR MARTIN COUNTY, FLORIDA
CASE NO: 2019-CA-000015
FREDERIC CHARLES GREER, III, and
MELISSA ANNE GREER, as Husband and
Wife, and FREDERIC CHARLES GREER, III
and MELISSA ANNE GREER, individually,
Plaintiffs,
vs.
MARTIN MEMORIAL MEDICAL CENTER,
INC. d/b/a MARTIN MEDICAL CENTER, a
Florida Corporation; KUNAL CHAUDHRY, M.D.;
and CARDIOLOGY ASSOCIATES OF STUART,
P.A., a Florida profit corporation,
Defendants.
/
AMENDED NOTICE OF TAKING UPDATE VIDEOTAPED DEPOSITION
DUCES TECUM -— (Amended to Add Videotaping only)
(Exhibit “A” Attached)
TO Peter J. Somera, Jr., Esq. & Paul M. Silva, M.D., Esq.
Somera & Silva, LLP
One Boca Place
2255 Glades Road, Suite 232W
Boca Raton, FL 33431
YOU, as attorney for the parties, are hereby notified that at the time and place listed below,
Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL
CENTER, A Florida Corporation, will take the deposition by oral examination for use as evidence
in the above-styled cause, of the following witness, who is requested to have with him at that time
the documents listed on Exhibit “A” attached:
WITNESS: Andrew Garrett
DATE/TIME: December 30, 2021 at 9:00 a.m.
LOCATION: Remotely via ZOOM. LINK information to be provided by Veritext Court
Reporting.
Remote Videographer Service to be provided by Veritext Legal Solutions, 1 East
Broward Blvd., # 902, Fort Lauderdale, FL 33301, Tel.: (954) 534-0253.
PLEASE TAKE FURTHER NOTICE that:
1 The deposition will be conducted remotely, using audio-visual conference
technology;
The court reporter will report the deposition from a location separate from the
witness;
Counsel for the parties and their clients will be participating from various,
separate locations, as designated in advance;
The witness and any party appearing by audio-visual conference will be
required to utilize a computer with audio-visual capability, or appear at location
with appropriate equipment (the parties will coordinate as to technical
requirements and other specifics in advance);
The witness will be required to provide government-issued identification
satisfactory to the court reporter, and this identification must be legible on
camera;
Each participating attorney and any other participants will be visible to all other
participants (unless the attorney appears telephonically), and their statements
will be audible to all participants;
No other participants will be permitted, unless by agreement and disclosed in
advance;
All exhibits will be provided simultaneously and electronically to the witness
and all participants;
9 The court reporter will record the testimony;
10. The deposition may be recorded electronically or may be recorded by a certified
videographer; and
11. Counsel for all parties will be required to stipulate on the record:
a. Their consent to this manner of taking deposition; and
b. Their waiver of any objection to this manner of taking deposition.
The deposition is being taken for purposes of discovery, in aid of execution, or for such
purposes as permitted under the rules of the Court.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this 16"" day of December, 2021, a copy of the foregoing
was served via the Florida E-Filing Portal to the parties on the attached service list.
STEARNS WEAVER MILLER
WEISSLER ALHADEFF & SITTERSON, P.A.
Attorneys for Martin Memorial Medical Center, Inc.
200 East Las Olas Blvd., Suite 2100
Fort Lauderdale, FL 33301
Phone: (954) 462-9500
Fax: (954) 462-9567
—
By:
THOMAS. AUBIN, ESQUIRE
FBN: 008060
taubin@stearnsweaver.com
MATTHEW S. PODOLNICK, ESQUIRE
FBN: 112126
mpodolnick@stearnsweaver.com
SERVICE LIST
Peter J. Somera Jr., Esq. Geoffrey N. Fieger, Esq.
Paul M. Silva, M.D., Esq. Fieger Law
Somera & Silva, LLP 19390 West Ten Mile Road
2255 Glades Road, Suite 232W Southfield, MI 48075
Boca Raton, FL 33431 Phone: (248) 355-5555
Phone: (561) 981-8881 Fax: (248) 355-5148
Fax: (561) 981-8887 G.Fieger Fiegerlaw.com
leadings somerasilva.com S.Teal@Fiegerlaw.com
litigation@somerasilva.com Co-Attorneys for Plaintiffs
Attorneys for Plaintiffs
Adam Richardson, Esq.
Bard D. Rockenbach, Esq.
Burlington & Rockenbach, P.A
444 West Railroad Avenue
West Palm Beach, FL 33401
Tel: 561-721-0400
ajr@FLAppellateLaw.com
bdr@FLAppellateLaw.com
fa@FLAy ellateLaw.cor
Appellate attorneys for Plaintiffs
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Filing # 140518509 E-Filed 12/16/2021 01:53:02 PM IN THE CIRCUIT COURT OF THE 19" JUDICIAL CIRCUIT IN AND FOR MARTIN COUNTY, FLORIDA CASE NO: 2019-CA-000015 FREDERIC CHARLES GREER, III, and MELISSA ANNE GREER, as Husband and Wife, and FREDERIC CHARLES GREER, III and MELISSA ANNE GREER, individually, Plaintiffs, vs. MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER, a Florida Corporation; KUNAL CHAUDHRY, M.D.; and CARDIOLOGY ASSOCIATES OF STUART, P.A., a Florida profit corporation, Defendants. / AMENDED NOTICE OF TAKING UPDATE VIDEOTAPED DEPOSITION DUCES TECUM -— (Amended to Add Videotaping only) (Exhibit “A” Attached) TO Peter J. Somera, Jr., Esq. & Paul M. Silva, M.D., Esq. Somera & Silva, LLP One Boca Place 2255 Glades Road, Suite 232W Boca Raton, FL 33431 YOU, as attorney for the parties, are hereby notified that at the time and place listed below, Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER, A Florida Corporation, will take the deposition by oral examination for use as evidence in the above-styled cause, of the following witness, who is requested to have with him at that time the documents listed on Exhibit “A” attached: WITNESS: Andrew Garrett DATE/TIME: December 30, 2021 at 9:00 a.m. LOCATION: Remotely via ZOOM. LINK information to be provided by Veritext Court Reporting. Remote Videographer Service to be provided by Veritext Legal Solutions, 1 East Broward Blvd., # 902, Fort Lauderdale, FL 33301, Tel.: (954) 534-0253. PLEASE TAKE FURTHER NOTICE that: 1 The deposition will be conducted remotely, using audio-visual conference technology; The court reporter will report the deposition from a location separate from the witness; Counsel for the parties and their clients will be participating from various, separate locations, as designated in advance; The witness and any party appearing by audio-visual conference will be required to utilize a computer with audio-visual capability, or appear at location with appropriate equipment (the parties will coordinate as to technical requirements and other specifics in advance); The witness will be required to provide government-issued identification satisfactory to the court reporter, and this identification must be legible on camera; Each participating attorney and any other participants will be visible to all other participants (unless the attorney appears telephonically), and their statements will be audible to all participants; No other participants will be permitted, unless by agreement and disclosed in advance; All exhibits will be provided simultaneously and electronically to the witness and all participants; 9 The court reporter will record the testimony; 10. The deposition may be recorded electronically or may be recorded by a certified videographer; and 11. Counsel for all parties will be required to stipulate on the record: a. Their consent to this manner of taking deposition; and b. Their waiver of any objection to this manner of taking deposition. The deposition is being taken for purposes of discovery, in aid of execution, or for such purposes as permitted under the rules of the Court. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this 16"" day of December, 2021, a copy of the foregoing was served via the Florida E-Filing Portal to the parties on the attached service list. STEARNS WEAVER MILLER WEISSLER ALHADEFF & SITTERSON, P.A. Attorneys for Martin Memorial Medical Center, Inc. 200 East Las Olas Blvd., Suite 2100 Fort Lauderdale, FL 33301 Phone: (954) 462-9500 Fax: (954) 462-9567 — By: THOMAS. AUBIN, ESQUIRE FBN: 008060 taubin@stearnsweaver.com MATTHEW S. PODOLNICK, ESQUIRE FBN: 112126 mpodolnick@stearnsweaver.com SERVICE LIST Peter J. Somera Jr., Esq. Geoffrey N. Fieger, Esq. Paul M. Silva, M.D., Esq. Fieger Law Somera & Silva, LLP 19390 West Ten Mile Road 2255 Glades Road, Suite 232W Southfield, MI 48075 Boca Raton, FL 33431 Phone: (248) 355-5555 Phone: (561) 981-8881 Fax: (248) 355-5148 Fax: (561) 981-8887 G.Fieger Fiegerlaw.com leadings somerasilva.com S.Teal@Fiegerlaw.com litigation@somerasilva.com Co-Attorneys for Plaintiffs Attorneys for Plaintiffs Adam Richardson, Esq. Bard D. Rockenbach, Esq. Burlington & Rockenbach, P.A 444 West Railroad Avenue West Palm Beach, FL 33401 Tel: 561-721-0400 ajr@FLAppellateLaw.com bdr@FLAppellateLaw.com fa@FLAy ellateLaw.cor Appellate attorneys for Plaintiffs