Document for CALZADA, ASHLEY vs. OSCEOLA REGIONAL HOSPITAL

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                                Filing # 199632696 E-Filed 05/31/2024 08:45:38 PM


        IN THE CIRCUIT COURT OF THE
        NINTH JUDICIAL CIRCUIT IN AND
        FOR OSCEOLA COUNTY, FLORIDA

        CASE NO: 2017-CA-000174 MP

        TODD COPELAND, Esquire as Guardian
        Ad Litem for J.C., a minor, and as Trustee
        of the J.C. Special Needs Trust, ASHLEY
        CALZADA and JUAN L. CALZADA,
        individually and on behalf of J.C., a minor,

               Plaintiffs,
        vs.
        T
        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,
        PL., 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.

                                                       /

                  DEFENDANTS, PEDIATRIX MEDICAL GROUP, INC., PEDIATRIX
                       MEDICAL GROUP OF FLORIDA, INC., MEDNAX, INC.,
                JOSE I. GIERBOLINI, M.D., and JUAN LONGHI, M.D.’S, EXHIBIT LIST
       Defendants, PEDIATRIX MEDICAL GROUP, INC., PEDIATRIX MEDICAL GROUP

OF FLORIDA, INC., MEDNAX, INC., JOSE I. GIERBOLINI, M.D., and JUAN LONGHI,

M.D., by and through their undersingted attorneys, pursuant to Rule 1.340(e) of the Florida Rule

of Civil Procedure, hereby file this Exhibit List purusant to the Court’s Order Following Case

Management Conference and Continuing Jury Trial dated February 4, 2024, as follows:

        1.
        2.       Records maintained by Eric Frendak, CRNA, Rodney Del Valle, M.D. and
                 Osceola Anesthesia Associates, PL pertaining to Plaintiff.

        3.       Records maintained by Luis Faveiro, MD pertaining to Plaintiff.

        4.       Records maintained by Jose Fernandez, MD pertaining to Plaintiff.

        5.       Records maintained by Federico Laham, MD pertaining to Plaintiff.

        6.       Records maintained by Saunders Prosthetics and Orthotics pertaining to
                 Plaintiff.

        7.       Records maintained by Lina Hernandez, MD pertaining to Plaintiff.

        8.       Records maintained by W. Raleigh Thompson, MD pertaining to Plaintiff.

        9.       Records maintained by Jorge J. Daaboul, MD pertaining to Plaintiff.

        10.      Records maintained by Carrousel Therapy Center pertaining to Plaintiff.

        11.      Records maintained by Bridge of Hope Therapy pertaining to Plaintiff.

        12.      Records maintained by Pediatric Neurology pertaining to Plaintiff.

        13.      Records and diagnostic images maintained by Osceola Regional Hospital, Inc.,
                 d/b/a Osceola Regional Medical Center pertaining to Plaintiff.

        14.      Records maintained by JMJ Family Practice, Inc. pertaining to Plaintiff.

        15.      Records maintained by Mid-Florida Woman's Center, Inc., Bhupendrakumar
                 M. Patel, M.D. pertaining to Plaintiff.

        16.      Records and imaging maintained by Osceola OB/GYN, Michael R. Denardis,
                 DO, pertaining to Plaintiff.
17.   Records maintained by Pediatrix Medical Group, Inc., Pediatrix Medical Group
      of Florida, Inc., Mednax, Inc., Jose I. Gierbolini, MD and Juan Longhi, MD
      pertaining to Plaintiff.

18.   Records maintained by OB Hospitalist Group, LLC, Ezer A. Ojeda, M.D.
      pertaining to Plaintiff.

19.   Records and diagnostic imaging maintained by Florida Hospital Kissimmee
      pertaining to Plaintiff.

20.   Records maintained by Ngoc Mihn Le, MD pertaining to Plaintiff.

21.   Records, diagnostic imaging, and pathology slides maintained by Orlando
      Health pertaining to Plaintiff.

22.   Records and diagnostic imaging maintained by Ashraf El Boy, MD, Child
      Neurology Center of Florida, P.A. pertaining to Plaintiff.

23.   Records, diagnostic imaging, and pathology slides maintained by Florida
      Hospital Orlando pertaining to Plaintiff.

24.   Records, diagnostic imaging, and pathology slides maintained by Florida
      Hospital pertaining to Plaintiff.

25.   Records maintained by Florida Pediatric Associates pertaining to Plaintiff.

26.   Records and diagnostic imaging maintained by United Cerebral Palsy of
      Florida pertaining to Plaintiff.

27.   Records maintained by Raymond F. Caron, MD, pertaining to Plaintiff.

28.   Records maintained by Federico Laham, MD, pertaining to Plaintiff.

29.   Records and diagnostic imaging maintained by Florida Gastroenterology Care
      for Children, pertaining to Plaintiff.

30.   Records and diagnostic imaging maintained by Nemours Children’s Hospital,
      pertaining to Plaintiff.

31.   Records and diagnostic imaging maintained by Nemours Children’s Health
      System, pertaining to Plaintiff.

32.   Records maintained by Children First Therapy Services, pertaining to Plaintiff

33.   Records maintained by Akrm Ald Husaini, M.D., pertaining to Plaintiff.
34.   Records maintained by Konda Reddy, M.D., pertaining to Plaintiff.

35.   Records maintained by Shaheem K. Shamji, DO, pertaining to Plaintiff.

36.   Records and radiology images maintained by Orlando Regional Medical
      Center, pertaining to Plaintiff.

37.   Records maintained by Orlando Health Physician Group, pertaining to Plaintiff.

38.   Records and diagnostic imaging maintained by St. Cloud Regional Medical
      Center/Medical Records Department, pertaining to Plaintiff.

39.   Records maintained by Family Care Center of Oviedo, pertaining to Plaintiff.

40.   Records maintained by Osceola Anesthesia Associates, pertaining to Plaintiff.

41.   Records and diagnostic imaging maintained by Hope Imaging, LLC.,
      pertaining to Plaintiff.

42.   Records and diagnostic imaging maintained by Arnold Palmer Hospital for
      Children. Pertaining to Plaintiff

43.   Records maintained by Professional Imaging Centers, pertaining to Plaintiff.

44.   Records maintained by Fernando Miranda, MD Bright Minds Institute,
      pertaining to Plaintiff.

45.   Records and diagnostic imaging maintained by Maxim Health Care Services
      pertaining to Plaintiff.

46.   Records and diagnostic imaging maintained by Night Lite Pediatrics pertaining
      to Plaintiff.

47.   Records and diagnostic imaging maintained by Raymond Knapp, Jr., MD
      pertaining to Plaintiff.

48.   Records and diagnostic imaging maintained by Children’s Ear Nose Throat &
      Allergy pertaining to Plaintiff.

49.   Records and diagnostic imaging maintained by Children’s 1st Therapy Service,
      Inc pertaining to Plaintiff.

50.   Records and diagnostic imaging maintained by Edgepark Medical Services
      pertaining to Plaintiff.

51.   Records maintained by CVS Pharmacy, pertaining to Plaintiff.
52.   Records maintained by Walgreen Company, pertaining to Plaintiff.

53.   Records maintained by Publix Pharmacy, pertaining to Plaintiff.

54.   Records maintained by WellCare Health Staywell, pertaining to Plaintiff.

55.   Video, exhibits and deposition transcript of Eric Frendak, CRNP taken 6/6/18.

56.   Video, exhibits and deposition transcript of Bhupendrakumar Patel, MD taken
      6/19/18.

57.   Video, exhibits and deposition transcript of Jose Gierbolini, MD taken 2/13/19.

58.   Video, exhibits and deposition transcript of Juan Longhi, MD taken 3/11/19.

59.   Video, exhibits and deposition transcript of Michael R. Denardis, DO taken
      7/25/18.

60.   Video, exhibits and deposition transcript of Rodney Del Valle, MD taken
      11/17/17.

61.   Video, exhibits and deposition transcript of Ashley Calzada taken 7/19/17.

62.   Video, exhibits and deposition transcript of Juan Calzada taken 7/19/17.

63.   Video, exhibits and deposition transcript of Jacque Altomare, RN taken
      8/24/20.

64.   Video, exhibits and deposition transcript of Craig Lichtblau, MD taken 10/3/23.

65.   Video, exhibits and deposition transcript of Sean Mahan, MD taken 9/25/23.

66.   Video, exhibits and deposition transcript of J. Carlos Maggi, MD taken
      10/12/23.

67.   Video, exhibits and deposition transcript of Martin Gubernick, MD taken
      9/19/23.

68.   Video, exhibits and deposition transcript of Carolyn Salafia, MD taken 12/5/23.

69.   Video, exhibits and deposition transcript of William Rhine, MD taken 12/6/23.

70.   Video, exhibits and deposition transcript of Jose Ramon Fernandez, M.D. taken
      12/7/17
71.   Video, exhibits and deposition transcript of Aaron Caughey, MD taken 1/10/24.
72.   Video, exhibits and deposition transcript of Ngoc Minh Dang Le, MD taken
      8/20/21.

73.   Video, exhibits and deposition transcript of Anthony Rodriguez, MD taken
      2/22/24.

74.   Video, exhibits and deposition transcript of Eric Harris, MD taken 2/26/24.

75.   Video, exhibits and deposition transcript of John Thorp, Jr., MD taken 2/27/24.

76.   Video, exhibits and deposition transcript of Neel Madan, MD taken 3/4/24.

77.   Video, exhibits and deposition transcript of Nicholas Guerina, MD taken
      3/26/24

78.   Video, exhibits and deposition transcript of Baha Sibai, MD taken 3/14/24.

79.   Video, exhibits and deposition transcript of Michael Duchowry, MD taken
      3/11/24.

80.   Video, exhibits and deposition transcript of Patrick Gorman, PsyD. taken
      10/17/23.

81.   Video, exhibits and deposition transcript of Scot Silverstein taken 10/23/23.

82.   Video, exhibits and deposition transcript of Robin Steinhorn, MD.

83.   Video, exhibits and deposition transcript of Kristi Kirby.

84.   Video, exhibits and deposition transcript of Jon Burroughs, MD.

85.   Video, exhibits and deposition transcript of Shanedelle Norford, MD.

86.   Video, exhibits and deposition transcript of Suzanne Baird, CPN, RN.

87.   All posts, including photographs, uploaded or otherwise added to any social
      networking sites or blogs, including, but not limited to, Facebook.com,
      Myspace.com, Twitter.com, Instagram, or any similar web sites for the
      decedent and the plaintiff.

88.   Any and all radiology images and/or films pertaining to this matter.

89.   Any and all blow-ups or medical records pertaining to this matter.

90.   Any and all depositions taken in this action including videotaped depositions.
91.    Any and all exhibits to any deposition taken in this action.

92.    Any and all curriculum vitae for expert witnesses disclosed by the Plaintiff in
       this matter.

93.    All documents, records or items produced or relied upon by any expert
       witness for any party in this case.

94.    Enlargements of any exhibits for use at trial.

95.    Any and all medical literature relevant to any issue in this case.

96.    Any and all demonstrative aids for trial including possible anatomical charts.

97.    Any and all exhibits disclosed on Plaintiff’s Exhibit List.

98.    All exhibits revealed as discovery continues.

99.    Any and all photographs and/or videos taken of Plaintiff.

100.   Any and all documents reflecting payments received or due from collateral
       sources for Plaintiff’s economic damages.

101.   All documents described in depositions, interrogatories, requests for
       admission and responses thereto, and all other pleadings in this case.

102.   Reports done by all individuals including but not limited to, physicians,
       nursing personnel, rehabilitation experts, therapists, teachers, medical
       technicians or any other individual who has examined or who has provided
       medical care, attention, or therapy, either rehabilitative, psychological or any
       other services, to Plaintiff.

103.   Any and all reports from timely disclosed expert witnesses including any and
       all attachments not limited to photographs, diagrams or notes.

104.   All pleadings, requests to produce, or interrogatories filed in this case and
       attachments.

105.   Any and all rebuttal and impeachment materials.

106.   This Defendant reserves the right to update/amend this exhibit list up to five
       (5) days prior to the trial of this case.


                     CERTIFICATE OF SERVICE
       I HEREBY CERTIFY that on the 31st day of May, 2024, I electronically filed the

foregoing using the Florida Courts e-filing Portal which will send a notice of electronic filing to

the following parties: Maria D. Tejedor, Esquire, Diez-Arguelles & Tejedor, P.A., 505 N Mills

Ave, Orlando, FL         32803, mail@theorlandolawyers.com; leah@theorlandolawyers.com;

ruth@theorlandolawyers.com; Thomas E. Dukes, III, Esquire and David A. Zika, Esquire,

McEwan, Martinez, Dukes & Hall, P.A., 108 East Central Boulevard, Orlando, FL 32801,

dzika@mmdorl.com; NOS@mmdorl.com; Walter Tache, Esquire, Tache Bronis Christianson &

Descalzo, P.A., 150 SE 2nd Street, Ste 600, Miami, FL 33131, service@tachebronis.com;

wtache@tachebronis.com; service@tachebronis.com and David S. Nelson, Esquire, La Cava &

Jacobson,    P.A.,   501    E.    Kennedy     Blvd.,    Ste   1250,    Tampa,     FL        33602,

dnelson@lacavajacobson.com; llacava@lacavajacobson.com; lnader@lacavajacobson.com.



                                              /s/ Patrick H. Telan
                                              Patrick H. Telan, Esquire
                                              Florida Bar No. 973874
                                              Marshall McKinstry, Esquire
                                              Florida Bar No. 1003059
                                              Counsel for Defendants, PEDIATRIX MEDICAL
                                              GROUP, INC., PEDIATRIX MEDICAL GROUP
                                              OF FLORIDA, INC., MEDNAX, INC., JOSE I.
                                              GIERBOLINI, M.D., and JUAN LONGHI, M.D.
                                              Telan, Meltz, Wallace & Eide, P.A.
                                              901 North Lake Destiny Road, Ste 450
                                              Maitland, FL 32751
                                              Phone: (407) 423-9545 -Fax: (407) 425-7104
                                              Email: enotice@triallawfla.com
                                                       phtelan@triallawfla.com
                                                       khill@triallawfla.com