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Filing # 142675668 E-Filed 01/26/2022 11:14:01 AM
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;
MARTIN MEMORIAL MEDICAL
CENTER, INC., d/b/a CLEVELAND
CLINIC TRADITION HOSPITAL; and
MARTIN MEMORIAL PHYSICIAN
CORPORATION, INC., d/b/a MARTIN
HEALTH PHYSICIAN GROUP,
Defendants.
____________________________/
NOTICE OF TAKING DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the undersigned attorneys will take the deposition of:
NAME: ROBERT HOLLOWAY, M.D.
DATE AND TIME: March 10, 2022 at 10:00 a.m.
PLACE: Via Zoom
upon oral examination before UNIVERSAL COURT REPORTING, Notary Public, or any other
Notary Public or other officer authorized by law to take depositions in the State of Florida. The
oral examination will continue from day to day until completed. The deposition is being taken for
the purpose of discovery, for use at trial,or for such other purposes as are permitted under the
Florida Rules of Civil procedure in such cases.
CASE NO. 21000610CAAXMX
Deponent is to bring with him/her the following:
1. Your complete file in connection with your evaluation of the issues involved in this lawsuit,
including, but not limited to any and all correspondence, e-mails, records, medical records,
radiology films, CD’s, DVD’s, depositions or other documents.
2. All correspondence, reports, notations, calculations or other documents prepared by you or
your assistants, which relate to this lawsuit.
3. All notes created by you.
4. Any and all documents, treatises, articles, diagrams, drawings, anatomical models,
textbooks or book chapters which you relied upon in formulating your opinions.
5. All medical and scientific publications, articles, abstracts, book chapters or presentations
authored by you, which relate to the issues involved in this lawsuit.
6. All models, illustrations, photographs or exhibits which you intend to utilize at the time of
trial.
7. Any tables or charts referred to or utilized by you in formulating your opinions.
8. All time records, ledgers, and bills prepared with regard to your expert services in this
lawsuit.
9. Any records or documents which reflect information about expert testimony you have
provided in the last 3 years.
10. Documents which reflect the names of cases in which you have testified as an expert
witness in the last 3 years.
11. A list of cases that you have prepared with regard to any disclosure required in a Federal
court action in the last 3 years.
12. Your current Curriculum Vitae.
If the records are maintained in an electronic format, please produce all records via e-
mail, CD, USB flash drive, or a ShareFile link.
IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00,
PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE-
APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF
YOUR INVOICE.
-2-
CASE NO. 21000610CAAXMX
Name: Margaret Carlton (deceased)
WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida
ePortal to: Bonnie Navin, Esquire, bonnie@rubensteinlaw.com, efabricant@rubensteinlaw.com,
eservice@rubensteinlaw.com; James L. White III, Esquire, white@bobolaw.com,
latour@bobolaw.com ; Thomas G. Aubin, Esquire, taubin@stearnsweaver.com;
mpetruk@stearnsweaver.com ; on this 26th day of January, 2022.
/s/ Robert E. Paradela
Robert E. Paradela, Esquire
Florida Bar No. 842095
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
In accordance with the Americans With Disabilities Act, persons with
disabilities needing a special accommodation to participate in this proceeding
should contact the undersigned attorney’s secretary at the address and phone
number given above not later than seven (7) days prior to the proceeding. If
hearing impaired, (TDD) 1-800-955-8770 via Florida Relay Service.
-3-
Preview
Filing # 142675668 E-Filed 01/26/2022 11:14:01 AM 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; MARTIN MEMORIAL MEDICAL CENTER, INC., d/b/a CLEVELAND CLINIC TRADITION HOSPITAL; and MARTIN MEMORIAL PHYSICIAN CORPORATION, INC., d/b/a MARTIN HEALTH PHYSICIAN GROUP, Defendants. ____________________________/ NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersigned attorneys will take the deposition of: NAME: ROBERT HOLLOWAY, M.D. DATE AND TIME: March 10, 2022 at 10:00 a.m. PLACE: Via Zoom upon oral examination before UNIVERSAL COURT REPORTING, Notary Public, or any other Notary Public or other officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. The deposition is being taken for the purpose of discovery, for use at trial,or for such other purposes as are permitted under the Florida Rules of Civil procedure in such cases. CASE NO. 21000610CAAXMX Deponent is to bring with him/her the following: 1. Your complete file in connection with your evaluation of the issues involved in this lawsuit, including, but not limited to any and all correspondence, e-mails, records, medical records, radiology films, CD’s, DVD’s, depositions or other documents. 2. All correspondence, reports, notations, calculations or other documents prepared by you or your assistants, which relate to this lawsuit. 3. All notes created by you. 4. Any and all documents, treatises, articles, diagrams, drawings, anatomical models, textbooks or book chapters which you relied upon in formulating your opinions. 5. All medical and scientific publications, articles, abstracts, book chapters or presentations authored by you, which relate to the issues involved in this lawsuit. 6. All models, illustrations, photographs or exhibits which you intend to utilize at the time of trial. 7. Any tables or charts referred to or utilized by you in formulating your opinions. 8. All time records, ledgers, and bills prepared with regard to your expert services in this lawsuit. 9. Any records or documents which reflect information about expert testimony you have provided in the last 3 years. 10. Documents which reflect the names of cases in which you have testified as an expert witness in the last 3 years. 11. A list of cases that you have prepared with regard to any disclosure required in a Federal court action in the last 3 years. 12. Your current Curriculum Vitae. If the records are maintained in an electronic format, please produce all records via e- mail, CD, USB flash drive, or a ShareFile link. IF THE COST OF PRODUCTION OF THE REQUESTED DOCUMENTS EXCEEDS $100.00, PRE-APPROVAL MUST BE OBTAINED FROM OUR OFFICE. WITHOUT PRE- APPROVAL FOR THE CHARGE, WE WILL NOT BE RESPONSIBLE FOR PAYMENT OF YOUR INVOICE. -2- CASE NO. 21000610CAAXMX Name: Margaret Carlton (deceased) WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida ePortal to: Bonnie Navin, Esquire, bonnie@rubensteinlaw.com, efabricant@rubensteinlaw.com, eservice@rubensteinlaw.com; James L. White III, Esquire, white@bobolaw.com, latour@bobolaw.com ; Thomas G. Aubin, Esquire, taubin@stearnsweaver.com; mpetruk@stearnsweaver.com ; on this 26th day of January, 2022. /s/ Robert E. Paradela Robert E. Paradela, Esquire Florida Bar No. 842095 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 In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact the undersigned attorney’s secretary at the address and phone number given above not later than seven (7) days prior to the proceeding. If hearing impaired, (TDD) 1-800-955-8770 via Florida Relay Service. -3-