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Filing # 139143244 E-Filed 11/24/2021 10:50:40 AM
IN THE CIRCUIT COURT OF THE ISTH
JUDICIAL CIRCUIT OF FLORIDA, IN AND
FOR PALM BEACH COUNTY
JANE DOE, GENERAL JURISDICTION DIVISION
Plaintiff, Case No: 50-2020-CA-014445-XXXX-MB
v.
BOCA RATON REGIONAL HOSPITAL,
INC. d/b/a BOCA RATON REGIONAL
HOSPITAL, and DEVON BRIGANTI,
Defendants.
PLAINTIFF’S POLICIES AND PROCEDURES REQUEST TO PRODUCE TO
DEFENDANT, BOCA RATON REGIONAL HOSPITAL, INC. D/B/A BOCA RATON
REGIONAL HOSPITAL
Plaintiff, JANE DOE, by and through the undersigned counsel, request, pursuant to Rule
1.350 of the Florida Rules of Civil Procedure, that the above named Defendant, produce and permit
Plaintiff's counsel to inspect and copy each of the following documents*:
1. Provide a copy of the Defendant’s table of contents and/or index for ALL of the hospital
policies and procedures.
2. Provide copies of all electronic non-privileged communications and/or information,
including e-mails, voice mails, texts, etc., stored in any manner and in any format concerning the
Patient. This includes emails to and from physicians about this patient. Please provide a
privilege log if claiming privilege.
3. Provide copies of all non-privileged reports, correspondence, or other writings
generated by or on behalf of any consultant to the hospital concerning the care and treatment of
Patients during the Patient’s residency. Please provide a privilege log if claiming privilege.
'** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/24/2021 10:50:40 AM ***Case No.: 50-2020-CA-014445-XXXX-MB
Pl’s Policies and Procedures RFP to BRRH
Page 2 of 4
4. Provide any and all non-privileged reports or data compilations that concern the status
or condition of Patients and were prepared by and/or sent to corporate officers or supervisors
during the hospitalization in question. Please provide a privilege log if claiming privilege.
5. Please provide color copies of all policies and procedures regarding preventing sexual
abuse.
6. Please provide color copies of all policies and procedures regarding reporting sexual
abuse.
7. Please provide color copies of all policies and procedures regarding maintaining staff
to patient ratios.
8. Provide any and all medical records of Teri Davis at Boca Raton Regional Hospital
from January 1, 2010 — today.
9. Please provide color copies of any and all photographs taken of the Patient.
“If you intend to assert a privilege to any of the above requests, provide a privilege log for each
response, specifying the document in question and the specific privilege.
"Documents" shall include, but not be limited to all non-identical copies of writings, drawings,
graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from
which information can be obtained, translated, if necessary, by the party to whom the request is
directed through detection devices into reasonably usable form. “Documents” also includes all
electronic data as well as application metadata and system metadata.
Where multiple identical copies of the same document exist, only one copy may be
produced as long as the production response clearly indicates the distribution, and retention ofCase No.: 50-2020-CA-014445-XXXX-MB
Pl’s Policies and Procedures RFP to BRRH
Page 3 of 4
each copy. Where multiple copies of the same document are not identical in any respect, a copy
of each non-identical version of the document must be produced.
IT HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
E- Mail to all counsel on the attached list, this 24th day of November 2021.
/s/ David J. Brevda, Esq.
David J. Brevda
Florida Bar No.: 1008373
Senior Justice Law Firm
7700 Congress Ave., Suite 3216
Boca Raton, Florida 33487
Phone: (561) 717-0813
Fax: (561) 708-6781
Email: eservice@seniorjustice.com
Attorney for Plaintiff(s)COUNSEL LIST
RoseMarie Antonacci-Pollock, Esq.
Florida Bar No.: 509752
Donald E. Guerrazzi, Esq.
Florida Bar No.: 116178
FALK, WAAS, HERNANDEZ, SOLOMON,
MENDLESTEIN & DAVIS, P.A.
Attorneys for Boca Raton Regional Hospital, Inc.
d/b/a Boca Raton Regional Hospital
1900 NW Corporate Blvd., Suite 210-E
Boca Raton, FL 33431
Telephone: (561) 367-2510
Fax: (305) 447-1777
Email: ServiceRMAntonacci@falkwaas.com
Julie N. Pagni, Esq,
Florida Bar No.: 111459
Pagni Law, PLLC
Attorney for Devon Briganti
9510 Listow Ter
Boynton Beach, FL 33472-2718
Phone: (954) 817-3441
Email: Pagnilaw@gmail.com
eservicepagnilaw@gmail.com
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Filing # 139143244 E-Filed 11/24/2021 10:50:40 AM IN THE CIRCUIT COURT OF THE ISTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR PALM BEACH COUNTY JANE DOE, GENERAL JURISDICTION DIVISION Plaintiff, Case No: 50-2020-CA-014445-XXXX-MB v. BOCA RATON REGIONAL HOSPITAL, INC. d/b/a BOCA RATON REGIONAL HOSPITAL, and DEVON BRIGANTI, Defendants. PLAINTIFF’S POLICIES AND PROCEDURES REQUEST TO PRODUCE TO DEFENDANT, BOCA RATON REGIONAL HOSPITAL, INC. D/B/A BOCA RATON REGIONAL HOSPITAL Plaintiff, JANE DOE, by and through the undersigned counsel, request, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that the above named Defendant, produce and permit Plaintiff's counsel to inspect and copy each of the following documents*: 1. Provide a copy of the Defendant’s table of contents and/or index for ALL of the hospital policies and procedures. 2. Provide copies of all electronic non-privileged communications and/or information, including e-mails, voice mails, texts, etc., stored in any manner and in any format concerning the Patient. This includes emails to and from physicians about this patient. Please provide a privilege log if claiming privilege. 3. Provide copies of all non-privileged reports, correspondence, or other writings generated by or on behalf of any consultant to the hospital concerning the care and treatment of Patients during the Patient’s residency. Please provide a privilege log if claiming privilege. '** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 11/24/2021 10:50:40 AM ***Case No.: 50-2020-CA-014445-XXXX-MB Pl’s Policies and Procedures RFP to BRRH Page 2 of 4 4. Provide any and all non-privileged reports or data compilations that concern the status or condition of Patients and were prepared by and/or sent to corporate officers or supervisors during the hospitalization in question. Please provide a privilege log if claiming privilege. 5. Please provide color copies of all policies and procedures regarding preventing sexual abuse. 6. Please provide color copies of all policies and procedures regarding reporting sexual abuse. 7. Please provide color copies of all policies and procedures regarding maintaining staff to patient ratios. 8. Provide any and all medical records of Teri Davis at Boca Raton Regional Hospital from January 1, 2010 — today. 9. Please provide color copies of any and all photographs taken of the Patient. “If you intend to assert a privilege to any of the above requests, provide a privilege log for each response, specifying the document in question and the specific privilege. "Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices into reasonably usable form. “Documents” also includes all electronic data as well as application metadata and system metadata. Where multiple identical copies of the same document exist, only one copy may be produced as long as the production response clearly indicates the distribution, and retention ofCase No.: 50-2020-CA-014445-XXXX-MB Pl’s Policies and Procedures RFP to BRRH Page 3 of 4 each copy. Where multiple copies of the same document are not identical in any respect, a copy of each non-identical version of the document must be produced. IT HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E- Mail to all counsel on the attached list, this 24th day of November 2021. /s/ David J. Brevda, Esq. David J. Brevda Florida Bar No.: 1008373 Senior Justice Law Firm 7700 Congress Ave., Suite 3216 Boca Raton, Florida 33487 Phone: (561) 717-0813 Fax: (561) 708-6781 Email: eservice@seniorjustice.com Attorney for Plaintiff(s)COUNSEL LIST RoseMarie Antonacci-Pollock, Esq. Florida Bar No.: 509752 Donald E. Guerrazzi, Esq. Florida Bar No.: 116178 FALK, WAAS, HERNANDEZ, SOLOMON, MENDLESTEIN & DAVIS, P.A. Attorneys for Boca Raton Regional Hospital, Inc. d/b/a Boca Raton Regional Hospital 1900 NW Corporate Blvd., Suite 210-E Boca Raton, FL 33431 Telephone: (561) 367-2510 Fax: (305) 447-1777 Email: ServiceRMAntonacci@falkwaas.com Julie N. Pagni, Esq, Florida Bar No.: 111459 Pagni Law, PLLC Attorney for Devon Briganti 9510 Listow Ter Boynton Beach, FL 33472-2718 Phone: (954) 817-3441 Email: Pagnilaw@gmail.com eservicepagnilaw@gmail.com