On July 08, 118 a
Party Discovery
was filed
involving a dispute between
Rivera, Ninoshka,
and
Altomare, Rnc, Jacque,
Bout, Rn, Melissa,
Bowling, Rn, Glenda,
Coulborn, St, S.,
Diaz, Rn, Ivonne,
Hall, Rnc, Julie,
J. Rapha Medical, P.A. D B A Osceola Women And Fam,
Maki, Lance Md,
Medina, Tanya,
Mednax, Inc.,
Ob Hospitalist Group, Llc,
Ojeda, Ezer Md,
Osceola Regional Hospital, Inc.,
Pediatrix Medical Group Of Florida, Inc.,
Pera, M.D., Angelina,
Slone, Rt, Constance,
Torres, Rn, Angela,
Williams, Rn, Chantelle,
for CIRCUIT CIVIL
in the District Court of Osceola County.
Preview
Filing # 107232316 E-Filed 05/08/2020 11:13:47 AM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN AND
FOR OSCEOLA COUNTY, FLORIDA
CASE NO. 2011-CA-000197-MP
NINOSHKA RIVERA, individually and on
behalf of KEVIN TERRON, a minor,
Plaintiffs,
v.
OSCEOLA REGIONAL HOSPITAL, INC.
d/bla OSCEOLA REGIONAL MEDICAL
CENTER; OB HOSPITALIST GROUP, LLC;
MEDNAX, INC.; PEDIATRIX MEDICAL
GROUP OF FLORIDA, INC.; EZER OJEDA,
M.D.; LANCE MAKI, M.D.; ANGELINA
PERA, M.D.; JACQUE ALTOMARE, RNC;
ANGELA TORRES, RN; CHANTELLE
WILLIAMS, RN; S. COULBORN, ST;
IVONNE DIAZ, RN; JULIE HALL, RNC;
MELISSA BOUT, RN; GLENDA BOWLING,
RN; CONSTANCE SLONE, RT; TANYA
MEDINA, M.D.; J. RAPHA MEDICAL, P.A.
d/bla OSCEOLA WOMEN AND FAMILY
MEDICINE SPECIALISTS; and PEDIATRIX
MEDICAL GROUP, INC.,
Defendants.
/
NOTICE OF TAKING DEPOSITIONS DUCES TECUM
PLEASE TAKE NOTICE that, pursuant to the Florida Rules of Civil Procedure,
Defendants, PEDIATRIC MEDICAL GROUP OF FLORIDA, INC. and ANGELINA PERA,
MLD., will take the deposition set forth below:
DEPONENT DATE/TIME LOCATION
Anthony Rodrigues, M.D. Tuesday, 9/15/20; 4:30 pm TBD — Court Reporter’s Office
Boston, MA 02111upon oral examination before an Official Court Reporter, or a Notary Public in and for the State
of Maryland at Large, or some other officer duly authorized by law to take the deposition. This
deposition is being taken for the purposes of discovery, for use at trial, or for such other purposes
as are permitted under the Florida Rules of Civil Procedure.
The witness is to produce the items listed in the attachment.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on May 8, 2020, I electronically filed the foregoing with the
Clerk of the Court using the Florida E-Portal system, which will automatically furnish a copy hereof
via email to: Maria D. Tejedor, Esquire (mail@theorlandolawyers.com,
leah@theorlandolawyers.com).
/s/Henry W. Jewett II
JENNINGS L. HURT III, ESQUIRE
Florida Bar No.: 0238171
Email: jlh.service@rissman.com
HENRY W. JEWETT II, ESQUIRE
Florida Bar No. 0380024
Email: hwj.service@rissman.com
MEGAN J. NELSON, ESQUIRE
Florida Bar No.: 01015368
Email: mjn.service@rissman.com
Rissman, Barrett, Hurt,
Donahue, McLain & Mangan, P.A.
201 East Pine Street, 15th Floor
Orlando, FL 32802-4940
Telephone: (407) 839-0120
Attorneys for Defendants
JLH/HWJ/MJN/ked/5124ATTACHM
A professional resume or curriculum vitae summarizing your professional qualifications.
A copy of any texts, periodicals, articles or similar information authored by you in the field
in which you intend to testify as an expert witness, which support opinions you intend to or
may express at trial.
All time records, diaries and bills prepared and rendered in connection with your
investigation and evaluation of the issues involved in this lawsuit.
Your complete file in connection with your investigation and evaluation of the issues
involved in the lawsuit, including, but not limited to:
a. All documents furnished to you by anyone;
b. All documents you reviewed, prepared, referred to or relied upon in arriving at any of
your opinions or conclusions concerning the issues involved in the lawsuit, including
but not limited to, all texts, periodicals, articles, books or similar information;
c. Any notes, reports, letters, memoranda or written documentation prepared by you
relating to this matter.
d. Any notes, reports, letters, memoranda or written documentation received by you
relating to this matter;
e. All models, illustrations, photographs, exhibits or documents of any kind which you
intend or contemplate using to explain, illustrate or support testimony at trial.
A list of all cases in which you testified either at deposition or at trial, or both, during the
period of 1980 to the present, in any jurisdiction, at any time, under any circumstances,
before any court, tribunal or arbitration proceeding.
A hard copy of any and all e-mail communication by and among you and counsel for
plaintiff and any of counsel's representatives including secretaries, paralegals and legal
assistants, as well as a hard copy of any e-mail communication between you and any other
health care professional regarding this matter.
A hard copy of any and all e-mail communication by and among you and anyone else
concerning this matter.
Preview
Filing # 107232316 E-Filed 05/08/2020 11:13:47 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO. 2011-CA-000197-MP NINOSHKA RIVERA, individually and on behalf of KEVIN TERRON, a minor, Plaintiffs, v. OSCEOLA REGIONAL HOSPITAL, INC. d/bla OSCEOLA REGIONAL MEDICAL CENTER; OB HOSPITALIST GROUP, LLC; MEDNAX, INC.; PEDIATRIX MEDICAL GROUP OF FLORIDA, INC.; EZER OJEDA, M.D.; LANCE MAKI, M.D.; ANGELINA PERA, M.D.; JACQUE ALTOMARE, RNC; ANGELA TORRES, RN; CHANTELLE WILLIAMS, RN; S. COULBORN, ST; IVONNE DIAZ, RN; JULIE HALL, RNC; MELISSA BOUT, RN; GLENDA BOWLING, RN; CONSTANCE SLONE, RT; TANYA MEDINA, M.D.; J. RAPHA MEDICAL, P.A. d/bla OSCEOLA WOMEN AND FAMILY MEDICINE SPECIALISTS; and PEDIATRIX MEDICAL GROUP, INC., Defendants. / NOTICE OF TAKING DEPOSITIONS DUCES TECUM PLEASE TAKE NOTICE that, pursuant to the Florida Rules of Civil Procedure, Defendants, PEDIATRIC MEDICAL GROUP OF FLORIDA, INC. and ANGELINA PERA, MLD., will take the deposition set forth below: DEPONENT DATE/TIME LOCATION Anthony Rodrigues, M.D. Tuesday, 9/15/20; 4:30 pm TBD — Court Reporter’s Office Boston, MA 02111upon oral examination before an Official Court Reporter, or a Notary Public in and for the State of Maryland at Large, or some other officer duly authorized by law to take the deposition. This deposition is being taken for the purposes of discovery, for use at trial, or for such other purposes as are permitted under the Florida Rules of Civil Procedure. The witness is to produce the items listed in the attachment. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 8, 2020, I electronically filed the foregoing with the Clerk of the Court using the Florida E-Portal system, which will automatically furnish a copy hereof via email to: Maria D. Tejedor, Esquire (mail@theorlandolawyers.com, leah@theorlandolawyers.com). /s/Henry W. Jewett II JENNINGS L. HURT III, ESQUIRE Florida Bar No.: 0238171 Email: jlh.service@rissman.com HENRY W. JEWETT II, ESQUIRE Florida Bar No. 0380024 Email: hwj.service@rissman.com MEGAN J. NELSON, ESQUIRE Florida Bar No.: 01015368 Email: mjn.service@rissman.com Rissman, Barrett, Hurt, Donahue, McLain & Mangan, P.A. 201 East Pine Street, 15th Floor Orlando, FL 32802-4940 Telephone: (407) 839-0120 Attorneys for Defendants JLH/HWJ/MJN/ked/5124ATTACHM A professional resume or curriculum vitae summarizing your professional qualifications. A copy of any texts, periodicals, articles or similar information authored by you in the field in which you intend to testify as an expert witness, which support opinions you intend to or may express at trial. All time records, diaries and bills prepared and rendered in connection with your investigation and evaluation of the issues involved in this lawsuit. Your complete file in connection with your investigation and evaluation of the issues involved in the lawsuit, including, but not limited to: a. All documents furnished to you by anyone; b. All documents you reviewed, prepared, referred to or relied upon in arriving at any of your opinions or conclusions concerning the issues involved in the lawsuit, including but not limited to, all texts, periodicals, articles, books or similar information; c. Any notes, reports, letters, memoranda or written documentation prepared by you relating to this matter. d. Any notes, reports, letters, memoranda or written documentation received by you relating to this matter; e. All models, illustrations, photographs, exhibits or documents of any kind which you intend or contemplate using to explain, illustrate or support testimony at trial. A list of all cases in which you testified either at deposition or at trial, or both, during the period of 1980 to the present, in any jurisdiction, at any time, under any circumstances, before any court, tribunal or arbitration proceeding. A hard copy of any and all e-mail communication by and among you and counsel for plaintiff and any of counsel's representatives including secretaries, paralegals and legal assistants, as well as a hard copy of any e-mail communication between you and any other health care professional regarding this matter. A hard copy of any and all e-mail communication by and among you and anyone else concerning this matter.