On July 08, 129 a
No Value
was filed
involving a dispute between
Simon Sally,
and
Asperilla Mark Md,
Asperilla Mark Md Pa,
Charlotte Medical Asscoi,
Colunga Frank Md,
Constine Ronald Md,
Dale Greenberg Md,
Estepa Samual Md,
Khalidi Nasir Md,
Khalidi Sakina Md,
Levy Baker Constine Et A,
Maas Carlos E Md,
Maas Carlos E Md Pa,
Mickelson Chris Md,
Moopen Moiden Md,
Moopen Moiden Md Pa,
Nandigam Bala Md,
Primary Care Physicians,
St Josephs Emergency Med,
Thomasz K Wazny Md Pa,
Wazny Thomasz K Mc,
for MALPRACTICE - CA
in the District Court of Charlotte County.
Preview
IN 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,
og
vs. =
—=
==2
MARK ASPERILLA, M.D., MARK ASPERILLA,
=—o90
3B “ct
M_D., P.A., a Florida Corporation, DALE GREEN-
BERG, M.D., RONALD CONSTINE, M.D., LEVY,
==os ey
ae
==S°o9 ey
BAKER, CONSTINE & GREENBERG, M.D., P.A., a25
a Florida Corporation, SAMUEL ESTEPA, M.D., .
wo
NASIR KHALIDI, M.D., NASIR KHALIDI & SAKINA 88
>s oO
KHALIDI, M.D., P.A., a Florida Corporation, and
CONRAD EPPING KOERPER, M.D., COLEMAN & Us g3
CS
CASTELLON, M.D., P.A., a/k/a CHARLOTTE == oo
== No
RADIOLOGY GROUP and BON SECOURS-ST. Sn 3
JOSEPH HOSPITAL, a Florida Coporation es
of
Defendants.
MOTION TO COMPEL ANSWERS TO EXPERT
WITNESS INTERROGATORIES TO MARK ASPERILLA
COMES NOW the Plaintiff SALLY SIMON, as Personal Representative of the Estate
of
MICHAEL SIMON, by and through the undersigned counsel. and moves to compel answers
to
Expert Witness Interrogatories dated August 29, 2000 to Mark Asperilla and as grounds
therefore
states:
1 Plaintiff served Expert Witness Interrogatories on Defendant Mark Asperill
a on
August 29, 2000. The time to respond has expired and no responses have been
provided. IMAGED
WHEREFORE, the Plaintiff would respectfully move for an Order compelling DP
answers
CULMO & CULMO, P.A., 2400 SOUTH DIXIE HIGHW
AY, SUITE 100, MIAMI, FL 33133 + (308) a56-4004
to these interrogatories.
CERTIFICATE OF GOOD FAITH
Movant counsel certifies that a bona fide effort to agree or to narrow the issues on the
motions(s) noticed has been made with opposing counsel or that, because of time considerations,
such effort has not yet been made, but will be made prior to the scheduled hearing.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served on ALL
COUNSEL OF RECORD this “day of December, 2000.
Respectfully submitted,
CULMO & CULMO, P.A.
2400 South Dixie Highway
Suite 100
Miami, Florida 33133
Telephone: 305-856-4004
Fax: 305-854-5445
By:
Thqmas A. Culmo
Fla. Bar No. 775479
FACASESSIMON\PLEADING \Aperillamcompexpt rogs
CULMO & CULMO, P.A., 2400 SOUTH DIXIE HIGHWAY, SUITE 100, MIAMI, FL 33133 + (305) 856-4004
Preview
IN 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, og vs. = —= ==2 MARK ASPERILLA, M.D., MARK ASPERILLA, =—o90 3B “ct M_D., P.A., a Florida Corporation, DALE GREEN- BERG, M.D., RONALD CONSTINE, M.D., LEVY, ==os ey ae ==S°o9 ey BAKER, CONSTINE & GREENBERG, M.D., P.A., a25 a Florida Corporation, SAMUEL ESTEPA, M.D., . wo NASIR KHALIDI, M.D., NASIR KHALIDI & SAKINA 88 >s oO KHALIDI, M.D., P.A., a Florida Corporation, and CONRAD EPPING KOERPER, M.D., COLEMAN & Us g3 CS CASTELLON, M.D., P.A., a/k/a CHARLOTTE == oo == No RADIOLOGY GROUP and BON SECOURS-ST. Sn 3 JOSEPH HOSPITAL, a Florida Coporation es of Defendants. MOTION TO COMPEL ANSWERS TO EXPERT WITNESS INTERROGATORIES TO MARK ASPERILLA COMES NOW the Plaintiff SALLY SIMON, as Personal Representative of the Estate of MICHAEL SIMON, by and through the undersigned counsel. and moves to compel answers to Expert Witness Interrogatories dated August 29, 2000 to Mark Asperilla and as grounds therefore states: 1 Plaintiff served Expert Witness Interrogatories on Defendant Mark Asperill a on August 29, 2000. The time to respond has expired and no responses have been provided. IMAGED WHEREFORE, the Plaintiff would respectfully move for an Order compelling DP answers CULMO & CULMO, P.A., 2400 SOUTH DIXIE HIGHW AY, SUITE 100, MIAMI, FL 33133 + (308) a56-4004 to these interrogatories. CERTIFICATE OF GOOD FAITH Movant counsel certifies that a bona fide effort to agree or to narrow the issues on the motions(s) noticed has been made with opposing counsel or that, because of time considerations, such effort has not yet been made, but will be made prior to the scheduled hearing. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served on ALL COUNSEL OF RECORD this “day of December, 2000. Respectfully submitted, CULMO & CULMO, P.A. 2400 South Dixie Highway Suite 100 Miami, Florida 33133 Telephone: 305-856-4004 Fax: 305-854-5445 By: Thqmas A. Culmo Fla. Bar No. 775479 FACASESSIMON\PLEADING \Aperillamcompexpt rogs CULMO & CULMO, P.A., 2400 SOUTH DIXIE HIGHWAY, SUITE 100, MIAMI, FL 33133 + (305) 856-4004