Party Discovery: HILL, AS PERSONAL REPRESENTATIVE OF THE ESTATE OF MARGARET CARLTON DECEASED, CHELSEA vs. LOPEZ, LEONEL D.O.

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                                Filing # 143892325 E-Filed 02/14/2022 04:44:58 PM

        99159-7
           IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT IN AND FOR MARTIN
                                    COUNTY, FLORIDA

         CHELSEA HILL, as Personal                              CIRCUIT CIVIL DIVISION
         Representative of the Estate of
         MARGARET CARLTON, deceased,                            CASE NO. 21000610CAAXMX

               Plaintiff,

         vs.

         LEONEL LOPEZ, D.O.; PARAGON
         CONTRACTING SERVICES, LLC;
         MICHAEL MALTMAN, M.D.;
         TREASURE COAST TOPDOC, PLLC;



                                                                 Y
         MARTIN MEMORIAL MEDICAL
         CENTER, INC., d/b/a CLEVELAND



                                                               P
         CLINIC TRADITION HOSPITAL; and
         MARTIN MEMORIAL PHYSICIAN



                                             O
         CORPORATION, INC., d/b/a MARTIN
         HEALTH PHYSICIAN GROUP,

            Defendants.
         ____________________________/     C
                                    RESPONSE TO REQUEST TO PRODUCE

                  Defendant, Michael E. Maltman, M.D., by and through the undersigned attorneys, and

        pursuant to the applicable Fla. R. Civ. P., responds to Plaintiff’s Request to Produce dated

        01/03/2022 as follows:

            1. A professional resume or curriculum vitae summarizing each expert’s professional
                  qualifications.


                  RESPONSE: See attached.


            2. A copy of any medical texts, periodicals, articles or similar information authored by each
                  expert pertaining to the subject matter of his/her testimony in this case.


                  RESPONSE: Objection. Request to Produce No. 2 seems tailored to obtain expert
                  information outside of a deposition or interrogatory. Fla. R. Civ. P. 1.280(b)(5)
                                                                CASE NO. 21000610CAAXMX




   confined discovery methods that may be employed to obtain information from an
   expert to depositions and interrogatories, even though discovery is answered by the
   party. S mi t h v .E l d r ed , 96 So. 3d 1102, 1104 (Fla. 2012). Notwithstanding this
   objection, please see publications listed in expert CVs.

3. All time records, diaries and bills prepared and rendered in connection with each expert’s
   investigation and evaluation of the issues involved in this lawsuit.




                                                    Y
   RESPONSE: See attached.




                               O                  P
4. A copy of each expert’s file in connection with their investigation and evaluation of the
   issues involved in the lawsuit, including, but not limited to:



                             C
       A. All documents furnished to each expert by the Defendants.
       B. All documents reviewed, prepared, referred to or relied upon in arriving at any of
           the expert’s opinions or conclusions concerning the issues involved in the lawsuit,
           including, but not limited to, all medical texts, periodicals, articles, books or similar
           information.
       C. Any notes, reports, letters, memoranda or written documentation prepared by the
           expert relating to this matter.
       D. Any notes, reports, letters, memoranda or written documentation received by the
           Defendant’s counsel from the expert and sent to the expert relating to this matter.
       E. All models, illustrations, photographs, exhibits or documents of any kind which
           your expert(s) intend to contemplate using to explain, illustrate or support
           testimony at trial.


   RESPONSE: See attached.              (Complaint, Cleveland Clinic Medical records,
   Deposition Transcript of Diana Hofman, Ana Parano and Leonel Lopez, and Autopsy
   Report)


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                                                                  CASE NO. 21000610CAAXMX




   5. A list of all cases in which your expert(s) testified either at deposition or at trial, or both
       within the last ten (10) years, in any jurisdiction, at any time, under any circumstances,
       before any court, tribunal or arbitration proceeding.


       RESPONSE: Does not maintain any case list or trial testimony lists.


       WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida


eservice@rubensteinlaw.com;
latour@bobolaw.com;       Thomas
                                 James
                                       G.
                                            L.
                                                 Aubin,
                                                       P
                                                   White
                                                         Y
ePortal to: Bonnie Navin, Esquire, bonnie@rubensteinlaw.com, efabricant@rubensteinlaw.com,
                                                           III,   Esquire,
                                                           Esquire,
                                                                             white@bobolaw.com,
                                                                       taubin@stearnsweaver.com;




                                C O
mpetruk@stearnsweaver.com; on this 14th day of January, 2022.



                                             /s / J e s s i c a L .K a p la n
                                             Jessica L. Kaplan, Esquire
                                             Florida Bar No. 111568
                                             WICKER SMITH O'HARA MCCOY & FORD, P.A.
                                             Attorneys for Michael E. Maltman, M.D.
                                             515 E. Las Olas Boulevard
                                             SunTrust Center, Suite 1400
                                             Ft. Lauderdale, FL 33301
                                             Phone: (954) 847-4800
                                             Fax: (954) 760-9353
                                             ftlcrtpleadings@wickersmith.com




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                                                            CASE NO. 21000610CAAXMX




bonnie@rubensteinlaw.com, efabricant@rubensteinlaw.com, eservice@rubensteinlaw.com

white@bobolaw.com, latour@bobolaw.com

taubin@stearnsweaver.com; mpetruk@stearnsweaver.com


SERVICE OF COURT DOCUMENT: CASE NO.: 21000610CAAXMX Carlton, Margaret
(deceased) and Douglas Carlton v. Michael Maltman,




                                                 Y
 COURT:                                        IN THE CIRCUIT COURT OF THE 19TH




                                               P
                                               JUDICIAL CIRCUIT IN AND FOR MARTIN




                              O
                                               COUNTY, FLORIDA




                            C
 CASE NO.:                                     21000610CAAXMX

 CASE NAME:                                    Carlton, Margaret (deceased) and Douglas

                                               Carlton v. Michael Maltman, M.D.

 DOCUMENT(S) SERVED:                           INPUT TITLE OF DOCUMENT

 ATTORNEY SERVING DOCUMENT:                    Jessica L. Kaplan, Esquire

 ATTORNEY SERVING DOCUMENT PHONE:              Phone: (954) 847-4800




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