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Filing# 142837061 E-Filed 01/28/2022 09:44:26 AM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN
AND FOR BROWARD COUNTY, FLORIDA
CASE NO: CACE-21-016646
LISA VUNKANNON-ROBERTS as Personal
Representativeof the Estate of Douglas James
Roberts, deceased,
Plaintiff.
VS.
MARIA BELEN GAME, M.D. and PRONTO
URGENT CARE LLC,
Defendants.
i
NOTICE OF SERVING MEDICAL MALPRACTICE INTERROGATORIES
TO DEFENDANT, PRONTO URGENT CARE LLC
LISA
Plaintiff, VUNKANNON-ROBERTS as Personal Representativeof the Estate of
Douglas James Roberts, deceased, hereby Plaintiff notice that pursuant to Rule 1.340(e),
Florida
numbered
Rules of Civil Procedure, that Medical Malpractice Interrogatories 1 through 23 have
been directed to Defendant, PRONTO URGENT CARE LLC, this 28 )th
day of January, 2022.
I HEREBY CERTIFY that a true and correct copy of the foregoingwas sent via E-Serve
,th
to all this 28I day of January, 2022.
Counsel on the attached list,
/s/Edward V. Ricci
Edward V. Ricci
Florida Bar No.. 039079
Primary E-Mail: ?ricciteam@searcylaw.com
Searcy Denney Scarola Barnhart & Shipley,P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
Phone: (561) 686-6300
Fax: (561) 383-9503
Attorney for Plaintiff
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/28/2022 09:44:25 AM.****
Roberts, Douglas E/O vs. Pronto Urgent Care, et. al
Case No.: CACE-21-016646
Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care
COUNSEL LIST
Jonathon P. Lynn, Esquire
jlynn@ljglegal.com
Lori B. Lewellen, Esquire
11ewellen@ljglegal.com
La Cava Jacobson & Goodis, P.A.
4901 NW 17th Way, Suite 606
Fort Lauderdale, FL 33309
(754) 301-5060
Attorney for Defendants
2
MEDICAL MALPRACTICE - INTERROGATORIES TO DEFENDANT,
PRONTO URGENT CARE LLC
(Ifanswering for another person or entity,answer with respect to that person or unless
entity,
otherwise stated).
NOTE: When the word "Plaintiff' is are directed to be
mentioned, these interrogatories
answers regarding Douglas James Roberts.
1. What is the name and address of the person answeringthese interrogatories,
and, if
with the party to
possible,the person'sofficial positionor relationship whom the
interrogatoriesare directed?
2. List all formernames and when you were known by those names. State all
addresses where you have lived for the past ten years, the dates you lived at each
number, and your date of birth.
address,your social security
3 Have you ever been convicted of a crime, other than any juvenileadjudication,
which under the law under which you were convicted punishablewas by death or
imprisonment in excess of one year, or that involved dishonestyor a false statement
regardlessof the punishment? If so, state as to each conviction,the specificcrime
and the date and the place of conviction.
Roberts, Douglas E/O vs. Pronto Urgent Care, et. al
Case No.: CACE-21-016646
Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care
4. Describe any and policiesof insurance which you contend cover or may cover
all
you for the
allegations set forth in plaintiffs
complaint,detailingas to such policies:
the name o f the insurer,number o f the policy,the effective dates o f the policy,the
available limits of liability,and the name and address ofthe custodian ofthe policy.
5. Describe in detail how the incident described in the complainthappened, including
all actions taken by you to prevent the incident.
6. Describe in detail each act or omission on the part of any party to this lawsuit that
you contend constituted negligencethat was a contributing cause of the incident in
question.
7. State the facts upon which you rely for each affirmative defense in your answer.
8 Do you contend any person or entityother than you is,or may be, liable in whole
or part of the claims asserted againstyou in this lawsuit? If so, state the full name
and address of each such person or entity,the basis for your contention,the facts or
2
Roberts, Douglas E/O vs. Pronto Urgent Care, et. al
Case No.: CACE-21-016646
Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care
evidence upon which your contention is based, and whether or not you have notified
each such person or entityof your contention.
9- Were you charged with any violation of law (including any regulations or
ordinances)arisingout of the incident described in the complaint? If so, what was
the nature of the charge;what court or agency heard the charge;was any written
report prepared by anyone regardingthis charge,and, if so, what is the name and
address of the person or entitythat prepared the report, do you have a copy of the
report; and was the testimonyat any trial,
hearing,or other proceeding on the charge
recorded in any manner, and if so, what is the name and address of the person who
recorded the testimony?
10. names and addresses ofall persons who are believed or known by you, your
List the
agents or attorneys to have any knowledge concerning any of the issues in this
lawsuit;and specifythe subjectmatter about which the witness has knowledge.
11. Have you heard or do you know about any statements or remark made by or on
behalf of any party to this lawsuit,other than yourself,
concerningany issue in this
lawsuit? If so, state the name and address of each person who made the statement
3
Roberts, Douglas E/O vs. Pronto Urgent Care, et. al
Case No.: CACE-21-016646
Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care
or statements, the name and address of each person who heard it,and the date,time,
place and substance of each statement.
12. name and address ofevery person known by you, your agents or attorneys
State the
who has knowledge about, or possession,custody or control of any model, plat,
map, drawing, motion picture,video tape, or photograph pertainingto any fact or
issue involved in this controversy; and describe as to each, what such person has,
the name and address of the person who took or prepared it,and the date it was
taken or prepared.
13. Do you intend to call any expert witnesses at the trial ofthis case? If so, state as to
each such witness the name and business address of the witness, the witnesses
as an expert, the subjectmatter upon which the witness is expected
qualifications
to the substance of the facts and opinionsto which the witness
testify, is expected
and a summary of the grounds for each opinion.
to testify;
14. Have you made an agreement with anyone that would limit that to
party'sliability
anyone for any ofthe damages sued upon in this case? If so, state the terms ofthe
agreement and the partiesto it.
4
Roberts, Douglas E/O vs. Pronto Urgent Care, et. al
Case No.: CACE-21-016646
Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care
15. Please state if you have ever been a party, either plaintiff
or defendant, in a lawsuit
other than the present matter, and if so, state whether you were plaintiffor
defendant, the nature of the action,and the date and court in which such suit was
filed.
16. Please give us your entire educational background, startingwith your college
education and chronologicallyindicatingby date and place each school, college,
course of study, and honors received to the present time, including
by you up
internships, residencies,degrees received, board memberships, authorshipof any
books, articles or texts, includingthe names of those writingsand their location in
medical journals,awards or honors received,and continuingmedical education.
17. Please give us your entire professional
background up to the present time, including
dates of employment or association,the names of all physicianswith whom you
have practiced,the form of employment or business relationship such as whether
by partnership,corporation,sole proprietorship,and the dates of the relationships,
includinghospitalstaff privilegesand positions,and teachingexperience.
5
Roberts, Douglas E/O vs. Pronto Urgent Care, et. al
Case No.: CACE-21-016646
Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care
18. With respect to your libraryor usual place ofwork, give us the name, author,
office
name ofpublisher,and date ofpublicationof every medical book or article,
journal
or medical text, to which you had access, which deals with the overall subject
matter described in paragraph (whatever paragraph number that concerns
negligenceof the complaint). (In lieu of answering this interrogatory, you may
allow plaintiffscounsel to inspectyour libraryat a reasonable time).
19. If you believe there was any risk to you rendered to the plaintiff,
the treatment state
the nature of allrisks, including whether the risks were communicated to the
when, where and in what manner they were communicated; and whether
plaintiff;
any of the risks in fact occurred.
20. Tell us your experience in giving the kind of treatment or examination that you
rendered to the plaintiff before it was given to the plaintiff, giving us such
information as the approximate number of times you have given similar treatment
or examinations, when the prior treatment or examinations took place,and the
successful or unsuccessful nature of the outcome of that treatment or those
examinations.
6
Roberts, Douglas E/O vs. Pronto Urgent Care, et. al
Case No.: CACE-21-016646
Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care
21. to formulate the basis of a request to
Please identifywith sufficient particularity
produce all medical records of any kind of which you are aware which deal with
at any time, whether
the medical treatment or examinations furnished to the plaintiff
by you or another person or persons.
22. Please state whether any claim for medical malpracticehas ever been made against
you allegingfacts relatingto the same or similar subjectmatter as this lawsuit,and,
if so, state as to each such claim the names of the parties,
the claim number, the
of the claim, and the
date of the allegedincident,the ultimate disposition name of
your attorney, if any.
23. Were any adverse incident reports made which in any way pertainedto the care and
treatment of the plaintiff.
7
Roberts, Douglas E/O vs. Pronto Urgent Care, et. al
Case No.: CACE-21-016646
Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care
STATE OF
COUNTY OF
Sworn to (or affinned) and subscribed before me by means of
O Physicalpresence or O online notarization this day of ,20
By
(name of individual Acknowledging)
Individual identified by O Personal Knowledge O SatisfactoryEvidence, Type
(SEAL)
Notary Signature
Notary name
-
print
NOTARY PUBLIC, State of Florida
(Serialnumber, if any)
8
Preview
Filing# 142837061 E-Filed 01/28/2022 09:44:26 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE-21-016646 LISA VUNKANNON-ROBERTS as Personal Representativeof the Estate of Douglas James Roberts, deceased, Plaintiff. VS. MARIA BELEN GAME, M.D. and PRONTO URGENT CARE LLC, Defendants. i NOTICE OF SERVING MEDICAL MALPRACTICE INTERROGATORIES TO DEFENDANT, PRONTO URGENT CARE LLC LISA Plaintiff, VUNKANNON-ROBERTS as Personal Representativeof the Estate of Douglas James Roberts, deceased, hereby Plaintiff notice that pursuant to Rule 1.340(e), Florida numbered Rules of Civil Procedure, that Medical Malpractice Interrogatories 1 through 23 have been directed to Defendant, PRONTO URGENT CARE LLC, this 28 )th day of January, 2022. I HEREBY CERTIFY that a true and correct copy of the foregoingwas sent via E-Serve ,th to all this 28I day of January, 2022. Counsel on the attached list, /s/Edward V. Ricci Edward V. Ricci Florida Bar No.. 039079 Primary E-Mail: ?ricciteam@searcylaw.com Searcy Denney Scarola Barnhart & Shipley,P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Phone: (561) 686-6300 Fax: (561) 383-9503 Attorney for Plaintiff *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/28/2022 09:44:25 AM.**** Roberts, Douglas E/O vs. Pronto Urgent Care, et. al Case No.: CACE-21-016646 Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care COUNSEL LIST Jonathon P. Lynn, Esquire jlynn@ljglegal.com Lori B. Lewellen, Esquire 11ewellen@ljglegal.com La Cava Jacobson & Goodis, P.A. 4901 NW 17th Way, Suite 606 Fort Lauderdale, FL 33309 (754) 301-5060 Attorney for Defendants 2 MEDICAL MALPRACTICE - INTERROGATORIES TO DEFENDANT, PRONTO URGENT CARE LLC (Ifanswering for another person or entity,answer with respect to that person or unless entity, otherwise stated). NOTE: When the word "Plaintiff' is are directed to be mentioned, these interrogatories answers regarding Douglas James Roberts. 1. What is the name and address of the person answeringthese interrogatories, and, if with the party to possible,the person'sofficial positionor relationship whom the interrogatoriesare directed? 2. List all formernames and when you were known by those names. State all addresses where you have lived for the past ten years, the dates you lived at each number, and your date of birth. address,your social security 3 Have you ever been convicted of a crime, other than any juvenileadjudication, which under the law under which you were convicted punishablewas by death or imprisonment in excess of one year, or that involved dishonestyor a false statement regardlessof the punishment? If so, state as to each conviction,the specificcrime and the date and the place of conviction. Roberts, Douglas E/O vs. Pronto Urgent Care, et. al Case No.: CACE-21-016646 Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care 4. Describe any and policiesof insurance which you contend cover or may cover all you for the allegations set forth in plaintiffs complaint,detailingas to such policies: the name o f the insurer,number o f the policy,the effective dates o f the policy,the available limits of liability,and the name and address ofthe custodian ofthe policy. 5. Describe in detail how the incident described in the complainthappened, including all actions taken by you to prevent the incident. 6. Describe in detail each act or omission on the part of any party to this lawsuit that you contend constituted negligencethat was a contributing cause of the incident in question. 7. State the facts upon which you rely for each affirmative defense in your answer. 8 Do you contend any person or entityother than you is,or may be, liable in whole or part of the claims asserted againstyou in this lawsuit? If so, state the full name and address of each such person or entity,the basis for your contention,the facts or 2 Roberts, Douglas E/O vs. Pronto Urgent Care, et. al Case No.: CACE-21-016646 Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care evidence upon which your contention is based, and whether or not you have notified each such person or entityof your contention. 9- Were you charged with any violation of law (including any regulations or ordinances)arisingout of the incident described in the complaint? If so, what was the nature of the charge;what court or agency heard the charge;was any written report prepared by anyone regardingthis charge,and, if so, what is the name and address of the person or entitythat prepared the report, do you have a copy of the report; and was the testimonyat any trial, hearing,or other proceeding on the charge recorded in any manner, and if so, what is the name and address of the person who recorded the testimony? 10. names and addresses ofall persons who are believed or known by you, your List the agents or attorneys to have any knowledge concerning any of the issues in this lawsuit;and specifythe subjectmatter about which the witness has knowledge. 11. Have you heard or do you know about any statements or remark made by or on behalf of any party to this lawsuit,other than yourself, concerningany issue in this lawsuit? If so, state the name and address of each person who made the statement 3 Roberts, Douglas E/O vs. Pronto Urgent Care, et. al Case No.: CACE-21-016646 Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care or statements, the name and address of each person who heard it,and the date,time, place and substance of each statement. 12. name and address ofevery person known by you, your agents or attorneys State the who has knowledge about, or possession,custody or control of any model, plat, map, drawing, motion picture,video tape, or photograph pertainingto any fact or issue involved in this controversy; and describe as to each, what such person has, the name and address of the person who took or prepared it,and the date it was taken or prepared. 13. Do you intend to call any expert witnesses at the trial ofthis case? If so, state as to each such witness the name and business address of the witness, the witnesses as an expert, the subjectmatter upon which the witness is expected qualifications to the substance of the facts and opinionsto which the witness testify, is expected and a summary of the grounds for each opinion. to testify; 14. Have you made an agreement with anyone that would limit that to party'sliability anyone for any ofthe damages sued upon in this case? If so, state the terms ofthe agreement and the partiesto it. 4 Roberts, Douglas E/O vs. Pronto Urgent Care, et. al Case No.: CACE-21-016646 Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care 15. Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other than the present matter, and if so, state whether you were plaintiffor defendant, the nature of the action,and the date and court in which such suit was filed. 16. Please give us your entire educational background, startingwith your college education and chronologicallyindicatingby date and place each school, college, course of study, and honors received to the present time, including by you up internships, residencies,degrees received, board memberships, authorshipof any books, articles or texts, includingthe names of those writingsand their location in medical journals,awards or honors received,and continuingmedical education. 17. Please give us your entire professional background up to the present time, including dates of employment or association,the names of all physicianswith whom you have practiced,the form of employment or business relationship such as whether by partnership,corporation,sole proprietorship,and the dates of the relationships, includinghospitalstaff privilegesand positions,and teachingexperience. 5 Roberts, Douglas E/O vs. Pronto Urgent Care, et. al Case No.: CACE-21-016646 Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care 18. With respect to your libraryor usual place ofwork, give us the name, author, office name ofpublisher,and date ofpublicationof every medical book or article, journal or medical text, to which you had access, which deals with the overall subject matter described in paragraph (whatever paragraph number that concerns negligenceof the complaint). (In lieu of answering this interrogatory, you may allow plaintiffscounsel to inspectyour libraryat a reasonable time). 19. If you believe there was any risk to you rendered to the plaintiff, the treatment state the nature of allrisks, including whether the risks were communicated to the when, where and in what manner they were communicated; and whether plaintiff; any of the risks in fact occurred. 20. Tell us your experience in giving the kind of treatment or examination that you rendered to the plaintiff before it was given to the plaintiff, giving us such information as the approximate number of times you have given similar treatment or examinations, when the prior treatment or examinations took place,and the successful or unsuccessful nature of the outcome of that treatment or those examinations. 6 Roberts, Douglas E/O vs. Pronto Urgent Care, et. al Case No.: CACE-21-016646 Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care 21. to formulate the basis of a request to Please identifywith sufficient particularity produce all medical records of any kind of which you are aware which deal with at any time, whether the medical treatment or examinations furnished to the plaintiff by you or another person or persons. 22. Please state whether any claim for medical malpracticehas ever been made against you allegingfacts relatingto the same or similar subjectmatter as this lawsuit,and, if so, state as to each such claim the names of the parties, the claim number, the of the claim, and the date of the allegedincident,the ultimate disposition name of your attorney, if any. 23. Were any adverse incident reports made which in any way pertainedto the care and treatment of the plaintiff. 7 Roberts, Douglas E/O vs. Pronto Urgent Care, et. al Case No.: CACE-21-016646 Notice of Serving Medical Malpractice Interrogatoriesto Defendant, Pronto Urgent Care STATE OF COUNTY OF Sworn to (or affinned) and subscribed before me by means of O Physicalpresence or O online notarization this day of ,20 By (name of individual Acknowledging) Individual identified by O Personal Knowledge O SatisfactoryEvidence, Type (SEAL) Notary Signature Notary name - print NOTARY PUBLIC, State of Florida (Serialnumber, if any) 8