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Filing # 185620470 E-Filed 11/07/2023 11:12:56 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
CIVIL DIVISION
Case No.: 2017-CA-000174 MP
TODD COPELAND, Esquire as Guardian
Ad Litem for JARIEL CALZADA, a minor,
ASHLEY CALZADA and JUAN L. CALZADA,
Individually and on behalf of JARIEL CALZADA a minor,
Plaintiffs,
vs.
OSCEOLA REGIONAL HOSPITAL d/b/a
OSCEOLA REGIONAL MEDICAL CENTER;
ERIC FRENDAK, CRNA; OSCEOLA
OB/GYN; MICHAEL R. DENARDIS, D.O.;
OB HOSPITALIST GROUP, LLC; EZER A.
OJEDA, M.D.; OSCEOLA ANESTHESIA
ASSOCIATES, P.L.; RODNEY DEL VALLE, M.D.;
JMJ FAMILY PRACTICE, INC.; JOSE RAMON
FERNANDEZ, M.D.; MID-FLORIDA WOMAN’S
CENTER, INC.; BHUPENDRAKUMAR M.
PATEL, M.D.; PEDIATRIX MEDICAL GROUP, INC.;
PEDIATRIX MEDICAL GROUP OF FLORIDA, INC.;
MEDNAX, INC.; JOSE I. GIERBOLINI, M.D.;
JUAN LONGHI, M.D.; HCA, INC.; HCA HEALTH
SERVICES OF FLORIDA, INC.; AND HCA
HEALTHCARE SERVICES-FLORIDA, INC.,
Defendants.
______________________________________________/
DEFENDANT OSCEOLA REGIONAL HOSPITAL d/b/a OSCEOLA REGIONAL MEDICAL
CENTER’s NOTICE OF TAKING DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the undersigned attorneys will take the deposition of:
NAME: ANTHONY RODRIGUES, M.D. [to be produced by Plaintiff]
DATE & TIME: FEBRUARY 22, 2024 @ 4:30 P.M.
LOCATION: VIA ZOOM
[Zoom link to be provided by Lexitas]
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upon oral examination before LEXITAS, Notary Public, or any other Notary Public or officer
authorized by law to take depositions in the State of Florida. The oral examination will continue
from day to day until completed and is being taken for the purpose of discovery, for use at trial,
or for such other purposes as are permitted under the rules.
DEPONENT IS REQUESTED TO HAVE ALL ITEMS LISTED ON ATTACHED EXHIBIT A WITH
HIM AT HIS DEPOSITION.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 7th day of November 2023, the foregoing was
electronically filed with the Clerk of the Court using the Florida Court E-Portal System, which will
send a Notice of Electronic Filing to:
Maria D. Tejedor, Esq., FBN: 0095834
Diez-Arguelles & Tejedor, P.A., 505 N. Mills Ave., Orlando, FL 32803
(407) 705-2880
mail@theorlandolawyers.com
leah@theorlandolawyers.com
Counsel for the Plaintiffs
Thomas E. Dukes, III, Esq.
David A. Zika, Esq.
McEwan, Martinez & Dukes, P.A., 108 E. Central Blvd., Orlando, FL 32801
NOS@mmdorl.com; tdukes@mmdorl.com; dzika@mmdorl.com
Counsel for Defendants. Eric Frendak, CRNA, Rodney Del Valle, M.D. and
Osceola Anesthesia Associates, PL
Pierre J. Seacord, Esq., FBN: 796050
Tara S. Lopez, Esq., FBN: 91667
Buckley Seacord & Justice, P.A., P.O. Box 4922, Orlando, FL 32802-4922
Service-seacord@bsi-law.com; Service-lopez@bsj-law.com
Counsel for Defendants. Osceola OB/GYN and Michael R. Denardis, D.O.
Eric F. Ochotorena, Esq.
Edward M. Copeland, IV, Esq.
Christina M. Benitez, Esq.
Rissman, Barrett, Hurt, Donahue, McLain & Mangan, P.A.
1 N. Dale Mabry Highway, 11th Floor, Tampa, FL 33609
Efo.service@rissman.com; emc.service@rissman.com; Cmb.service@rissman.com
Counsel for Defendants OB Hospitalist Group, LLC, EzerA. Ojeda, M.D.
Patrick H. Telan, Esq., FBN: 973874
Marshall E. McKinstry, Esq., FBN: 1003059
Telan, Meltz Wallace & Eide, P.A.
901 N. Lake Destiny Road, Suite450
Maitland, FL 32751
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(407) 423-9545; (407) 425-7104 (fax)
Enotice@triallawfla.com; phtelan@triallawfla.com; cboals@triallawfla.com
Counsel for Defendants Pediatrix Medical Group, Inc., Pediatrix Medical Group
of Florida, Inc., Mednax, Inc., Jose I. Gierbolini, M.D., Juan Longhi, M.D.
Walter Tache, Esq.
Tache’ Bronis Christianson & Descalzo, P.A.
150 SE 2nd St., Suite 600, Miami, FL 33131
wtache@tachebronis.com; service@tachebronis.com
Co-Counsel for Defendant Osceola Regional Hospital
d/b/a Osceola Regional Medical Center
John D. Emmanuel
BUCHANAN INGERSOLL & ROONEY PC
401 East Jackson Street, Suite 2400, Tampa, FL 33602
813 222 8180; Fax No: 813 222 8189
John.emmanuel@bipc.com; Sabrina.storno@bipc.com
Counsel for Defendants HCA, Inc., HCA Healthcare Services of Florida, Inc. and HCA
Healthcare Services-Florida, Inc.
UavicCS. MeCson
David S. Nelson, Esq.
Florida Bar No.: 705780
La Cava Jacobson & Goodis, P.A.
501 East Kennedy Blvd., 12th Floor
Tampa, FL 33602
(813) 209-9611
(813) 209-9511 (fax)
LNader@LJGIegal.com
COUNSEL FOR DEFENDANTS
OSCEOLA REGIONAL HOSPITAL d/b/a
OSCEOLA REGIONAL MEDICAL CENTER
cc: Lexitas [via e-mail]
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EXHIBIT "A"
All requests are in reference to this lawsuit, i.e., regarding ASHLEY CALZADA and JUAN L.
CALZADA, individually and on behalf of JARIEL LUIS CALZADA OYUELA, a minor, and the
allegations against OSCEOLA REGIONAL HOSPITAL d/b/a OSCEOLA REGIONAL MEDICAL
CENTER
1) Your current curriculum vitae.
2) All photographs viewed and/or taken by or for you regarding this lawsuit.
3) Copies of all statements or depositions, whether written or recorded, that you have
reviewed in this lawsuit.
4) All published or non-published standards from any source, text, treatises, articles, manuals
and journals which you used or referred to in formulating your opinions relative to this
lawsuit.
5) Copies of all published articles written in part or whole by you concerning issues in this
lawsuit.
6) All reports you have prepared relating to your expert opinion in this lawsuit.
7) All notes, calculations and other data prepared by you in formulating your opinions in this
lawsuit.
8) All drawings, graphs, charts, illustrations and plans prepared by you in formulating your
opinion in this lawsuit.
9) All reports and/or any other test results, reports and documentation that have been
prepared by you or other sub-specialists who have examined and/or treated and/or tested
the property pertaining to this lawsuit.
10) Reports of other experts you have read in this case.
11) Any published monographs, treatises, manuals, articles, textbooks or other documents
which you have used as a reference and upon which you base your expert opinion, in
whole or in part, in this case.
12) Any correspondence between your office and Plaintiff's counsel in this case.
13) All correspondence that you have written or received from others with whom you might
have consulted in any capacity in this case.
14) All memoranda you have reviewed, prepared by the attorney who engaged you, an
investigator, paralegal or an adjuster in this case.
15) Copies of all documents reviewed by you regarding this lawsuit.
16) Copies of all billing and payment records regarding the work performed by you in this
lawsuit.
17) A listing of all lawsuits in which you have given deposition or trial testimony in the past five
(5) years.
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Preview
Filing # 185620470 E-Filed 11/07/2023 11:12:56 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CIVIL DIVISION Case No.: 2017-CA-000174 MP TODD COPELAND, Esquire as Guardian Ad Litem for JARIEL CALZADA, a minor, ASHLEY CALZADA and JUAN L. CALZADA, Individually and on behalf of JARIEL CALZADA a minor, Plaintiffs, vs. OSCEOLA REGIONAL HOSPITAL d/b/a OSCEOLA REGIONAL MEDICAL CENTER; ERIC FRENDAK, CRNA; OSCEOLA OB/GYN; MICHAEL R. DENARDIS, D.O.; OB HOSPITALIST GROUP, LLC; EZER A. OJEDA, M.D.; OSCEOLA ANESTHESIA ASSOCIATES, P.L.; RODNEY DEL VALLE, M.D.; JMJ FAMILY PRACTICE, INC.; JOSE RAMON FERNANDEZ, M.D.; MID-FLORIDA WOMAN’S CENTER, INC.; BHUPENDRAKUMAR M. PATEL, M.D.; PEDIATRIX MEDICAL GROUP, INC.; PEDIATRIX MEDICAL GROUP OF FLORIDA, INC.; MEDNAX, INC.; JOSE I. GIERBOLINI, M.D.; JUAN LONGHI, M.D.; HCA, INC.; HCA HEALTH SERVICES OF FLORIDA, INC.; AND HCA HEALTHCARE SERVICES-FLORIDA, INC., Defendants. ______________________________________________/ DEFENDANT OSCEOLA REGIONAL HOSPITAL d/b/a OSCEOLA REGIONAL MEDICAL CENTER’s NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersigned attorneys will take the deposition of: NAME: ANTHONY RODRIGUES, M.D. [to be produced by Plaintiff] DATE & TIME: FEBRUARY 22, 2024 @ 4:30 P.M. LOCATION: VIA ZOOM [Zoom link to be provided by Lexitas] 1 upon oral examination before LEXITAS, Notary Public, or any other Notary Public or officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed and is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the rules. DEPONENT IS REQUESTED TO HAVE ALL ITEMS LISTED ON ATTACHED EXHIBIT A WITH HIM AT HIS DEPOSITION. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 7th day of November 2023, the foregoing was electronically filed with the Clerk of the Court using the Florida Court E-Portal System, which will send a Notice of Electronic Filing to: Maria D. Tejedor, Esq., FBN: 0095834 Diez-Arguelles & Tejedor, P.A., 505 N. Mills Ave., Orlando, FL 32803 (407) 705-2880 mail@theorlandolawyers.com leah@theorlandolawyers.com Counsel for the Plaintiffs Thomas E. Dukes, III, Esq. David A. Zika, Esq. McEwan, Martinez & Dukes, P.A., 108 E. Central Blvd., Orlando, FL 32801 NOS@mmdorl.com; tdukes@mmdorl.com; dzika@mmdorl.com Counsel for Defendants. Eric Frendak, CRNA, Rodney Del Valle, M.D. and Osceola Anesthesia Associates, PL Pierre J. Seacord, Esq., FBN: 796050 Tara S. Lopez, Esq., FBN: 91667 Buckley Seacord & Justice, P.A., P.O. Box 4922, Orlando, FL 32802-4922 Service-seacord@bsi-law.com; Service-lopez@bsj-law.com Counsel for Defendants. Osceola OB/GYN and Michael R. Denardis, D.O. Eric F. Ochotorena, Esq. Edward M. Copeland, IV, Esq. Christina M. Benitez, Esq. Rissman, Barrett, Hurt, Donahue, McLain & Mangan, P.A. 1 N. Dale Mabry Highway, 11th Floor, Tampa, FL 33609 Efo.service@rissman.com; emc.service@rissman.com; Cmb.service@rissman.com Counsel for Defendants OB Hospitalist Group, LLC, EzerA. Ojeda, M.D. Patrick H. Telan, Esq., FBN: 973874 Marshall E. McKinstry, Esq., FBN: 1003059 Telan, Meltz Wallace & Eide, P.A. 901 N. Lake Destiny Road, Suite450 Maitland, FL 32751 2 (407) 423-9545; (407) 425-7104 (fax) Enotice@triallawfla.com; phtelan@triallawfla.com; cboals@triallawfla.com Counsel for Defendants Pediatrix Medical Group, Inc., Pediatrix Medical Group of Florida, Inc., Mednax, Inc., Jose I. Gierbolini, M.D., Juan Longhi, M.D. Walter Tache, Esq. Tache’ Bronis Christianson & Descalzo, P.A. 150 SE 2nd St., Suite 600, Miami, FL 33131 wtache@tachebronis.com; service@tachebronis.com Co-Counsel for Defendant Osceola Regional Hospital d/b/a Osceola Regional Medical Center John D. Emmanuel BUCHANAN INGERSOLL & ROONEY PC 401 East Jackson Street, Suite 2400, Tampa, FL 33602 813 222 8180; Fax No: 813 222 8189 John.emmanuel@bipc.com; Sabrina.storno@bipc.com Counsel for Defendants HCA, Inc., HCA Healthcare Services of Florida, Inc. and HCA Healthcare Services-Florida, Inc. UavicCS. MeCson David S. Nelson, Esq. Florida Bar No.: 705780 La Cava Jacobson & Goodis, P.A. 501 East Kennedy Blvd., 12th Floor Tampa, FL 33602 (813) 209-9611 (813) 209-9511 (fax) LNader@LJGIegal.com COUNSEL FOR DEFENDANTS OSCEOLA REGIONAL HOSPITAL d/b/a OSCEOLA REGIONAL MEDICAL CENTER cc: Lexitas [via e-mail] 3 EXHIBIT "A" All requests are in reference to this lawsuit, i.e., regarding ASHLEY CALZADA and JUAN L. CALZADA, individually and on behalf of JARIEL LUIS CALZADA OYUELA, a minor, and the allegations against OSCEOLA REGIONAL HOSPITAL d/b/a OSCEOLA REGIONAL MEDICAL CENTER 1) Your current curriculum vitae. 2) All photographs viewed and/or taken by or for you regarding this lawsuit. 3) Copies of all statements or depositions, whether written or recorded, that you have reviewed in this lawsuit. 4) All published or non-published standards from any source, text, treatises, articles, manuals and journals which you used or referred to in formulating your opinions relative to this lawsuit. 5) Copies of all published articles written in part or whole by you concerning issues in this lawsuit. 6) All reports you have prepared relating to your expert opinion in this lawsuit. 7) All notes, calculations and other data prepared by you in formulating your opinions in this lawsuit. 8) All drawings, graphs, charts, illustrations and plans prepared by you in formulating your opinion in this lawsuit. 9) All reports and/or any other test results, reports and documentation that have been prepared by you or other sub-specialists who have examined and/or treated and/or tested the property pertaining to this lawsuit. 10) Reports of other experts you have read in this case. 11) Any published monographs, treatises, manuals, articles, textbooks or other documents which you have used as a reference and upon which you base your expert opinion, in whole or in part, in this case. 12) Any correspondence between your office and Plaintiff's counsel in this case. 13) All correspondence that you have written or received from others with whom you might have consulted in any capacity in this case. 14) All memoranda you have reviewed, prepared by the attorney who engaged you, an investigator, paralegal or an adjuster in this case. 15) Copies of all documents reviewed by you regarding this lawsuit. 16) Copies of all billing and payment records regarding the work performed by you in this lawsuit. 17) A listing of all lawsuits in which you have given deposition or trial testimony in the past five (5) years. 4