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Filing # 101066347 E-Filed 01/03/2020 09:49:24 AM
IN THE CIRCUIT COURT OF THE
20™ JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
CASE NO. 11-2019-CA-004943-0001-XX
SHARON A. MARTIN, as the Personal
Representative of the Estate of
JAMES K. MARTIN, deceased, and on
behalf of herself as surviving spouse,
and the surviving minor children,
SAGE EMILY MARTIN and
SHENNA GRACE MARTIN,
Plaintiffs,
Vv.
MAZEN K. ABUAWAD, MLD., F&S
RADIOLOGY, P.C., SHERIDAN
RADIOLOGY MANAGEMENT
SERVICES, INC., SHERIDAN
HEALTHCARE INC., ENVISION
PHYSICIAN SERVICES, LLC.,
ENVISION HEALTHCARE
CORPORATION, NCHMD, INC. and
NAPLES COMMUNITY HOSPITAL, INC,,
Defendants..
_ = —./
PLAINTIFFS’ REQUEST FOR PRODUCTION
TO-DEFENDANT, NAPLES.COMMUNITY HOSPITAL, INC.
Plaintiffs, SHARON A. MARTIN, as the Personal Representative of the Estate of JAMES
K. MARTIN, deceased, and on behalf of herself as surviving spouse, and the surviving minor
children, SAGE EMILY MARTIN and SHENNA GRACE MARTIN, through undersigned
counsel, propound this Request for Production to Defendant NAPLES COMMUNITY
Law Offices Grossman. Roth Yaffa Cohen, P.A.
2525 Ponce de Leon Boulevard, Suite 1150, Coral Gables, Florida 33134 T 305.442.8666 F 305.285.1668
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 01/03/2020 12:01:01 PMHOSPITAL, INC. The Defendant is to respond to said Request for Production on or before forty-
five (45) days of receipt of service.
1. All contracts, agreements and written memorandums of any kind, including
employment agreements and indemnity agreements, between you and any other Defendant in this
cause of action that were in effect at any point in time since 2016.
2. Any and all documents sufficient to identify who or what paid your wages, and any
bonuses you received, since 2016.
3. Any and all policies of liability insurance, primary, excess or otherwise, which
might insure to the benefit of the Plaintiffs by providing for payment of a part or all of any
judgment rendered in favor of the Plaintiffs against you.
4. Any and all policies of liability insurance, primary, excess or otherwise, which
might insure to the benefit of the Plaintiffs by providing for payment of a part or all of any
judgment rendered in favor of the Plaintiffs against any other Defendant in this cause of action.
I HEREBY. CERTIFY that the foregoing:document was filed through the Florida e-Filing
Portal and sérved upon the Defendants along with the Summons and Complaint this BS day of
January, 2020.
GROSSMAN ROTH YAFFA COHEN, P.A.
Attorneys for Plaintiffs
2525 Ponce de Leon Blvd., Suite 1150
Coral Gables, Florida 33134
Telephone: 305-442-8666
Facsimile: 305-285-1668
E-Mail: :nar@grossmanroth.com
Leah & Bor
NEAL A. ROTH ~
Fla. Bar No. 220876
By.
Law Offices Grossman Roth Yafla Cohen, P.A,
2525 Ponce de Leon Boulevard, Suite 1150, Coral Gables, Florida 33134 T 305.442.8666 F 305.285.1668
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Filing # 101066347 E-Filed 01/03/2020 09:49:24 AM IN THE CIRCUIT COURT OF THE 20™ JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIRCUIT CIVIL DIVISION CASE NO. 11-2019-CA-004943-0001-XX SHARON A. MARTIN, as the Personal Representative of the Estate of JAMES K. MARTIN, deceased, and on behalf of herself as surviving spouse, and the surviving minor children, SAGE EMILY MARTIN and SHENNA GRACE MARTIN, Plaintiffs, Vv. MAZEN K. ABUAWAD, MLD., F&S RADIOLOGY, P.C., SHERIDAN RADIOLOGY MANAGEMENT SERVICES, INC., SHERIDAN HEALTHCARE INC., ENVISION PHYSICIAN SERVICES, LLC., ENVISION HEALTHCARE CORPORATION, NCHMD, INC. and NAPLES COMMUNITY HOSPITAL, INC,, Defendants.. _ = —./ PLAINTIFFS’ REQUEST FOR PRODUCTION TO-DEFENDANT, NAPLES.COMMUNITY HOSPITAL, INC. Plaintiffs, SHARON A. MARTIN, as the Personal Representative of the Estate of JAMES K. MARTIN, deceased, and on behalf of herself as surviving spouse, and the surviving minor children, SAGE EMILY MARTIN and SHENNA GRACE MARTIN, through undersigned counsel, propound this Request for Production to Defendant NAPLES COMMUNITY Law Offices Grossman. Roth Yaffa Cohen, P.A. 2525 Ponce de Leon Boulevard, Suite 1150, Coral Gables, Florida 33134 T 305.442.8666 F 305.285.1668 FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 01/03/2020 12:01:01 PMHOSPITAL, INC. The Defendant is to respond to said Request for Production on or before forty- five (45) days of receipt of service. 1. All contracts, agreements and written memorandums of any kind, including employment agreements and indemnity agreements, between you and any other Defendant in this cause of action that were in effect at any point in time since 2016. 2. Any and all documents sufficient to identify who or what paid your wages, and any bonuses you received, since 2016. 3. Any and all policies of liability insurance, primary, excess or otherwise, which might insure to the benefit of the Plaintiffs by providing for payment of a part or all of any judgment rendered in favor of the Plaintiffs against you. 4. Any and all policies of liability insurance, primary, excess or otherwise, which might insure to the benefit of the Plaintiffs by providing for payment of a part or all of any judgment rendered in favor of the Plaintiffs against any other Defendant in this cause of action. I HEREBY. CERTIFY that the foregoing:document was filed through the Florida e-Filing Portal and sérved upon the Defendants along with the Summons and Complaint this BS day of January, 2020. GROSSMAN ROTH YAFFA COHEN, P.A. Attorneys for Plaintiffs 2525 Ponce de Leon Blvd., Suite 1150 Coral Gables, Florida 33134 Telephone: 305-442-8666 Facsimile: 305-285-1668 E-Mail: :nar@grossmanroth.com Leah & Bor NEAL A. ROTH ~ Fla. Bar No. 220876 By. Law Offices Grossman Roth Yafla Cohen, P.A, 2525 Ponce de Leon Boulevard, Suite 1150, Coral Gables, Florida 33134 T 305.442.8666 F 305.285.1668