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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CIVIL ACTION
SALLY SIMON, as Personal Representative
of the Estate of MICHAEL SIMON,
Plaintiff,
vs.
Case No. 00-120 CA
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 Corporation, THOMAS K. WANZY, M.D.,
THOMAS K. WANZY, M.D., P.A., a Florida Corporation,
BALA K. NANDIGAM, M.D., CHARLOTTE MEDICAL
ASSOCIATES, P.A., a Florida Corporation, MOIDEN
MOOPEN, M.D., MOIDEN MOOPEN, M.D., P.A., a
Florida Corporation, CARLOS E. MAAS, M.D.,
CARLOS E. MAAS, M.D., P.A., a Florida Corporation,
NASIR KHALIDI, M.D., NASIR KHALIDI & SAKINA an
KHALID, M.D., P.A., a Florida Corporation, ST. JOSEPHS
EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation,
FRANK COLUNGA, M.D., CHRIS MICKELSON., M.D.,
Defendants.
/
DEFENDANTS‘ REQUEST TO PRODUCE TO PLAINTIFF _
COME NOW, the Defendants, DALE GREENBERG, M.D., RONALD
CONSTINE, .D., and LEVY, BAKER, CONSTINE & GREENBERG, M.D., P.A by and
through their undersigned counsel, and in accordance with the applicable Rules of
Civil Procedure, requests the Plaintiff to produce to the undersigned attorney within
thirty (30) days of the date of this request or at such other and reasonable time as
might be mutually agreed upon by counsel for the parties, for the purpose of
inspection and/or copying, all items enumerated on the attached Schedule "A".
Defendants believe that they are entitled te examine said items pursuant to
Charlotte County Clerk
Rule 1.350 of the Florida Rules of Civil Procedure 1082907 Date : 04/06/00 - 10:55:53 id: 8
Case#: 00000120CA Pa les: 0004
IM kt i l
LAW OFFICES GEORGE, HARTZ, LUNDEEN, FLAGG & FULMER
SUITE 402 BARNETT CENTRE, 2000 MAIN STREET, FORT MYIRS, FLORIDA 33901 TELEPHONE (9411337 7787
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the above and foregoing
has been furnished by U. S. Mail to Thomas A. Culmo, P.A., Grove Professional
Building, 2950 S.W. 27" Avenue, Suite 100, Miami, FL 33133 and Dennis A.
Koltun, P.A., 7101 S.W. 102™ Avenue, Miami, FL 33173this 4 day of
Mretow
February, 2000.
GEORGE, HARTZ, LUNDEEN & FULMER
Attorneys for Defendants DALE
GREENBERG, M.D., RONALD CONSTINE,
M.D., and LEVY, BAKER, CONSTINE &
GREENBERG, M_D., P.A.
2000 Main Street, Suite 402
Fort Myers, Florida 33901
941/337-7787
941/337-4303 facsimile
r
Ahog
-
By:
Craig R. vens
Fla. Bar Np. 608149
LAW OFFICES GEORGE, HARTZ, LINDEEN, FLAGG & FULMER
SUITE 402 BARNETT CENTRE, 2000 MAIN STREET, FORT MYERS, FLORIDA 3390! TELEPHONE (9411337 7787
SCHEDULE "A"
Any and all medical bills, hospital bills, nursing bills, drug and/or
pharmaceutical bills and/or any and all other bills, statements or services and
memoranda supporting payment or future payment which allegedly support
decedent's claim for damages due to alleged personal injury as a result of the
alleged incident, as well as hospital records and reports, and the medical
and/or rehabilitative physician or dentist or health care provider regarding the
decedent's, mental or physical condition following and/or arising from the
incidents and injuries in question.
Any and all photographs, drawings and/or motion pictures of the
decedent depicting any and all alleged injuries or damages allegedly
suffered by the decedent, as a result of the incident or injuries in
question, and including any photographs of the decedent taken within
six months preceding this accident or occurrence.
Any and all statements or records and/or reports or oral statements
previously made by these Defendants, their agents, servants or
employees, referable to any matter material in this cause.
Any and all records, documents and materials reflecting and/or
pertaining in any manner or form to any payments made to the
decedent, or on his behalf, arising as a result of the incident or
incidents allegedly in issue in the instant cause, by or pursuant to:
a) The United States Social Security Act; any Federal, State or local
disability act; any other public programs providing medical expenses,
disability payments or other similar benefits.
b} Any health, sickness or disability income insurance, and any
other similar benefits.
c) Any contract or agreements or any group, organization, partnership or
corporation to provide, pay for, or reimburse costs of hospital, medical
or other health care services.
d) Any contractual or voluntary wage continuation plan provided by any
employers of the Plaintiff or any other system intended to provide
wages during any period of alleged disability of such individual.
e) Any other collateral source whatsoever pertaining to damages incurred
relative to the alleged negligence herein.
True copies of any and all Federal !ncome Tax returns, W-2 withholding tax
statements and any and all business records, paid receipts and other
memoranda in the possession, custody or control of the Plaintiff
indicating gross income from self-employment, employment, salaries,
commissions, bonuses, investments, credits and/or reimbursements for
business expenses, for the past ten (10) years together with and in
addition to 1997 income to date.
Any and all expert reports or correspondence with experts, authored
by said experts, to be used at the trial of this cause.
Any and all diaries, logs, etc. kept by the Plaintiffs concerning any of
the facts or circumstances involved in this case.
A copy of the death certificate and any and all autopsy reports.
All estate documents.
10 All funeral bills.
11 A copy of your marriage license.
12 A copy of the birth certificate of all survivors and children.
Preview
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION SALLY SIMON, as Personal Representative of the Estate of MICHAEL SIMON, Plaintiff, vs. Case No. 00-120 CA 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 Corporation, THOMAS K. WANZY, M.D., THOMAS K. WANZY, M.D., P.A., a Florida Corporation, BALA K. NANDIGAM, M.D., CHARLOTTE MEDICAL ASSOCIATES, P.A., a Florida Corporation, MOIDEN MOOPEN, M.D., MOIDEN MOOPEN, M.D., P.A., a Florida Corporation, CARLOS E. MAAS, M.D., CARLOS E. MAAS, M.D., P.A., a Florida Corporation, NASIR KHALIDI, M.D., NASIR KHALIDI & SAKINA an KHALID, M.D., P.A., a Florida Corporation, ST. JOSEPHS EMERGENCY MEDICAL PHYSICIANS, a Florida Corporation, FRANK COLUNGA, M.D., CHRIS MICKELSON., M.D., Defendants. / DEFENDANTS‘ REQUEST TO PRODUCE TO PLAINTIFF _ COME NOW, the Defendants, DALE GREENBERG, M.D., RONALD CONSTINE, .D., and LEVY, BAKER, CONSTINE & GREENBERG, M.D., P.A by and through their undersigned counsel, and in accordance with the applicable Rules of Civil Procedure, requests the Plaintiff to produce to the undersigned attorney within thirty (30) days of the date of this request or at such other and reasonable time as might be mutually agreed upon by counsel for the parties, for the purpose of inspection and/or copying, all items enumerated on the attached Schedule "A". Defendants believe that they are entitled te examine said items pursuant to Charlotte County Clerk Rule 1.350 of the Florida Rules of Civil Procedure 1082907 Date : 04/06/00 - 10:55:53 id: 8 Case#: 00000120CA Pa les: 0004 IM kt i l LAW OFFICES GEORGE, HARTZ, LUNDEEN, FLAGG & FULMER SUITE 402 BARNETT CENTRE, 2000 MAIN STREET, FORT MYIRS, FLORIDA 33901 TELEPHONE (9411337 7787 CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished by U. S. Mail to Thomas A. Culmo, P.A., Grove Professional Building, 2950 S.W. 27" Avenue, Suite 100, Miami, FL 33133 and Dennis A. Koltun, P.A., 7101 S.W. 102™ Avenue, Miami, FL 33173this 4 day of Mretow February, 2000. GEORGE, HARTZ, LUNDEEN & FULMER Attorneys for Defendants DALE GREENBERG, M.D., RONALD CONSTINE, M.D., and LEVY, BAKER, CONSTINE & GREENBERG, M_D., P.A. 2000 Main Street, Suite 402 Fort Myers, Florida 33901 941/337-7787 941/337-4303 facsimile r Ahog - By: Craig R. vens Fla. Bar Np. 608149 LAW OFFICES GEORGE, HARTZ, LINDEEN, FLAGG & FULMER SUITE 402 BARNETT CENTRE, 2000 MAIN STREET, FORT MYERS, FLORIDA 3390! TELEPHONE (9411337 7787 SCHEDULE "A" Any and all medical bills, hospital bills, nursing bills, drug and/or pharmaceutical bills and/or any and all other bills, statements or services and memoranda supporting payment or future payment which allegedly support decedent's claim for damages due to alleged personal injury as a result of the alleged incident, as well as hospital records and reports, and the medical and/or rehabilitative physician or dentist or health care provider regarding the decedent's, mental or physical condition following and/or arising from the incidents and injuries in question. Any and all photographs, drawings and/or motion pictures of the decedent depicting any and all alleged injuries or damages allegedly suffered by the decedent, as a result of the incident or injuries in question, and including any photographs of the decedent taken within six months preceding this accident or occurrence. Any and all statements or records and/or reports or oral statements previously made by these Defendants, their agents, servants or employees, referable to any matter material in this cause. Any and all records, documents and materials reflecting and/or pertaining in any manner or form to any payments made to the decedent, or on his behalf, arising as a result of the incident or incidents allegedly in issue in the instant cause, by or pursuant to: a) The United States Social Security Act; any Federal, State or local disability act; any other public programs providing medical expenses, disability payments or other similar benefits. b} Any health, sickness or disability income insurance, and any other similar benefits. c) Any contract or agreements or any group, organization, partnership or corporation to provide, pay for, or reimburse costs of hospital, medical or other health care services. d) Any contractual or voluntary wage continuation plan provided by any employers of the Plaintiff or any other system intended to provide wages during any period of alleged disability of such individual. e) Any other collateral source whatsoever pertaining to damages incurred relative to the alleged negligence herein. True copies of any and all Federal !ncome Tax returns, W-2 withholding tax statements and any and all business records, paid receipts and other memoranda in the possession, custody or control of the Plaintiff indicating gross income from self-employment, employment, salaries, commissions, bonuses, investments, credits and/or reimbursements for business expenses, for the past ten (10) years together with and in addition to 1997 income to date. Any and all expert reports or correspondence with experts, authored by said experts, to be used at the trial of this cause. Any and all diaries, logs, etc. kept by the Plaintiffs concerning any of the facts or circumstances involved in this case. A copy of the death certificate and any and all autopsy reports. All estate documents. 10 All funeral bills. 11 A copy of your marriage license. 12 A copy of the birth certificate of all survivors and children.