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Filing # 163274879 E-Filed 12/19/2022 10:13:26 AM
IN THE CIRCUIT COURT OF THE
19™ JUDICIAL CIRCUIT IN AND FOR
MARTIN COUNTY, FLORIDA
CASE NO.: 2019CA000015
FREDERIC CHARLES GREER, III
and MELISSA ANNE GREER, as
Husband and Wife, and FREDERIC
CHARLES GREER, Il and
MELISSA ANNE GREER,
individually,
Plaintiffs,
vs.
MARTIN MEMORIAL MEDICAL
CENTER, INC., D/B/A MARTIN
MEDICAL CENTER, a Florida
Corporation, KUNAL CHAUDHRY,
MD, and CARDIOLOGY
ASSOCIATES OF STUART, P.A:, a
Florida Profit Corporation,
Defendants.
/
PLAINTIFF’S SEVENTH AMENDED EXHIBIT LIST
Plaintiff, FREDERIC CHARLES GREER, III] and MELISSA ANNE GREER, as
Husband and Wife, and FREDERIC CHARLES GREER, III and MELISSA ANNE GREER,
individually, hereby give notice that they may present the following items as exhibits at the trial
of this matter.
1 Any and all medical bills generated as a result of the medical care and treatment
of the Plaintiff, FREDERIC CHARLES GREER, IIL.
2. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III from: Sara Alvarez, LMHC /
PSL Counseling.
CASE NO.: 2019CA000015
3 Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III from: Gregorio Aquino, Jr., DDS
/ Tomalty Dental Care.
4 Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III from: Robert Barry, MD /
Gabriel Guerrero, MD / Robert Lemieux, MD / Martin Health Physician Group.
5 Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Ibrahim Bassell, EMT /
Donovan Bell, EMT / Orlando Fire Department.
6 Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Minda Butler, SLP / Ana
Kalinski, PT / Johana Moscoso, OT / Encompass Health Rehabilitation Hospital of Altamonte
Springs.
7 Any and all medical records, reports, diagnostic testing, interventions and results
generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES
GREER, III, from: Kunal Chaudhry, MD / Cardiology Associates of Stuart, PA.
8 Any and all medical records, reports, diagnostic testing, interventions and results
generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES
GREER, Ill, from: Community Home Health Services.
9 Any and all medical records, reports, diagnostic testing, interventions and results
generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES
GREER, III, from: Cora Physical Therapy.
10. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Michael Demasi, MD /
Care Now Urgent Care.
11. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Paul Dreyer, MD /
Nephrology Associates of Central Florida.
12. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Robert Eilers, MD.
Any and all medical records generated as a result of the medical care and
13.
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: David Fernandez, MD /
Hyperbaric Medicine & Wound Care Center.
CASE NO.: 2019CA000015
14. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Genesis Medical
Laboratory.
15. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Paul Gotkin, DPM /
Treasure Coast Podiatry Care.
16. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Robert lannacone, DPM.
17. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: William Kane, MD / Vero
Orthopedics Neurology.
18. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: E. Corry Maguire, DPM /
Orlando Foot & Ankle Clinic.
19. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: M. Joe Ma, MD, PhD /
Peter Pernicone, MD / Michael J. Radt, MD / Seema Shroff, MD, PhD / Charnajeet Singh, MD /
Tien-Anh, Tran, MD / Central Florida Pathology Associates, PA.
20. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Javier Marinez, MD /
Infectious Disease Consultants.
21. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Andrew Martin, MD /
Florida Diabetes & Endocrine Center.
22. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Jerome Obed, MD /
Broward Dermatology & Cosmetic Specialists.
23, Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Luis Olivera-Rodriguez,
MD / Gustavo Ruiz, MD / Mindful Behavioral Healthcare.
24. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Hal S. Pineless, DO,
FACN / NeuroCare Institute of Central Florida.
25. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Karin Sieger, PhD.
CASE NO.: 2019CA000015
26. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Shawn Sorensen, PhD.
27. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Vanessa Stavros, BSN,
RN, CCM, CLCP / Amerisys.
28. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, Ill, from: St. Lucie Eye Associates.
29. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Nicholas Suite, MD.
30. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, Ill, from: Jeffrey Sutton, MD / Lake
Worth Diagnostic Testing Group.
31. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: St. Lucie Cunty Fire
District.
32. Any and all medical records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, IIL from: Howard Tee, MD.
33. Any and all hospital records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Florida Hospital Orlando.
34, Any and all hospital records generated as a result of the medical care and
treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Florida Hospital
Transplant Institute.
35. Any and all hospital records, reports, diagnostic tests and results generated as a
result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, Ill,
from Martin Medical Center.
36. Any and all hospital records, reports, diagnostic tests and results generated as a
result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III,
from: St. Lucie Medical Center.
37. Any and all hospital records, reports, diagnostic tests and results generated as a
result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III,
from Tradition Medical Center.
38. Any and all insurance records of Cigna Insurance Company as the same pertains
to the Plaintiff, FREDERIC CHARLES GREER, III.
CASE NO.: 2019CA000015
39. Any and all employment records of Palm Beach Sheriff's Office as the same
pertains to the Plaintiff, FREDERIC CHARLES GREER, IIL.
40. Any and all pharmacy records of Publix Pharmacy as the same pertains to the
Plaintiff, FREDERIC CHARLES GREER, III.
41. Any and all pharmacy records of Walgreens Pharmacy as the same pertains to the
Plaintiff, FREDERIC CHARLES GREER, III.
42, Any and all Worker’s Compensation records of USIS as the same pertains to the
Plaintiff, FREDERIC CHARLES GREER, III.
43. Cardiac Cath Event/Computer Log, Martin Medical Center.
44, Interventional Services Department Cardiac Result report authored by Kunal
Chaudhry M.D. on 9/1/17.
45. 9/1/17 cardiac catheterization diagnostic imaging studies Martin Medical Center.
46. 9/1/17 echocardiogram ultrasounds Martin Medical Center.
47. All records, reports, diagnostic tests and results for FREDERIC CHARLES
GREER, III, from St. Lucie County Fire District.
48. Any and all photographs and/or video-tapes as the same pertain to the Plaintiff,
FREDERIC CHARLES GREER, III.
49. Pictures of Plaintiff dated July 24, 2018.
50. Pictures of Plaintiff with LVAD from September 2017.
51 Pictures of FREDERIC CHARLES GREER, III six months prior to January 18,
2019.
52 Pictures of Plaintiff after heart transplant take July 2018.
53 Pictures of Plaintiff three months prior to transplant.
54 Pictures of Plaintiff prior to accident.
55 Plaintiffs Facebook posts and photographs.
56 Any and all reports prepared by expert witnesses including, but not limited to,
medical reports, rehabilitative, life care plan, and economic reports in this case.
CASE NO.: 2019CA000015
57. Life Assistance, Rehab & Medical Management Plan for Home Report prepared
by Robert Eilers, MD.
58. Medical Care Cost Summary Report prepared by Ronald Missun, PhD.
59. Loss of Earning Capacity Report prepared by Ronald Missun, PhD.
60. Any and all income tax return as the same pertains to the Plaintiff, FREDERIC
CHARLES GREER, III.
6l. Any and all social security earnings statements.
62. Any and all policy and procedure manuals, safety guidelines, etc. for the
Defendant herein.
63. Cardiac Cath Lab Policy —
Balloon Angioplasty Procedure
Patient Room Set-up for Cardiac Cath Procedure.
Setting A Sterile Cardiac Cauterization Tray
Coronary Stent Procedure
Insertion of Intra-Aortic Balloon Catheter
Left Heart Catheterization
Stemi-Cardiac Alert
Cardiac Transfers Decision Tree From Tradition Medical (TMC)
Interventional Lab
Transcatheter Aortic Valve Replacement
Description Through Roles of Cath Lab Personnel
Printing Cardiac Cath Reports
Surgical Attire
Outpatient Admission To Cardiac Cath Holding Room
Roles of Cath Lab Personnel
Safety Guidelines
Utilization of Procedure Rooms During Radiology Special Procedure
Down Time
Cath Lab Scheduling Guidelines
64. Martin Memorial Medical Center - Medical Staff By-Laws.
65. Marketing Materials for Martin Medical Center and Dr. Chaudhry and his
employer.
66. Audit Trail of the electronic medical records for Martin Medical Center for
9/1/2017 for FREDERIC CHARLES GREER, III.
CASE NO.: 2019CA000015
67. Any and all records from Social Security Administration as the same pertains to
the Plaintiff, FREDERIC CHARLES GREER, III.
68. Any and all contracts involving the Defendant.
69. Frances Langford Heart Center Cardiac Catheterization Laboratory Co-Medical
Director Agreement.
70. High Performance Network Leadership Council Services Agreement.
71. Interventional Cardiology Pool Agreement.
72. Martin Memorial Medical Center, Inc. Interventional Cardiology Coverage
Agreement.
2. 2011 ACCF/AHA Guideline for Coronary Artery Bypass Graft Surgery.
74. 2011 ACCF/AHA/SCAI Guideline for Percutaneous Coronary Intervention.
75. 2014 AHA/ACC. Guideline for the Management of Patients with Non-ST-
Elevation Acute Coronary Syndromes.
76. Any and all medical illustrations, including cardiac catheterization and cardiac
echo enlargements and demonstrative aids.
77. Any and all diagrams.
78. Any and all mortality tables.
79 Any and all social security disability reports, forms, applications, medical records.
80. Any and all worker’s compensation reports, evaluations, bills, liens, payments,
medical records.
81. Any and all depositions and/or videotape depositions taken in this case and
exhibits attached thereto.
82. Any and all interrogatories and documents produced in response to requests for
production and discovery requests in this case.
83. Any and all correspondence in this case.
84. Any and all enlargements of medical records diagnostic imaging, including
cardiac catheterization and cardiac echo enlargements and demonstrative aids, medical bills,
photographs, etc. as the same pertains to this case.
CASE NO.: 2019CA000015
85. Records and images received from Martin Medical Center for Frederic Charles
Greer, III by Advent Health Orlando f/k/a Florida Hospital Orlando from Records Custodian
deposition take on March 20, 2020.
86. Records and images received from Martin Medical Center for Frederic Charles
Greer, III by Advent Health Orlando f/k/a Florida Hospital Orlando from Records Custodian
deposition take on May 22, 2020.
87. Florida Statute 395.1055 — Hospital Licensing and Regulation — Rules and
enforcement.
88. Plaintiff's Exhibit #1 attached to the deposition of David Walkonen taken on July
15, 2019.
89. Plaintiff's Exhibit #2 attached to the deposition of David Walkonen taken on July
15, 2019.
90. Plaintiff's Exhibit #3 attached to the deposition of David Walkonen taken on July
15, 2019.
91. Access log marked as Plaintiffs Exhibit #1 to the deposition Stephani Grace
taken on July 15, 2019.
92. Epic Electronic Health Records marked as Plaintiff's Exhibit #1 to the deposition
Stephani Grace taken on July 15, 2019.
93. Cardiac Cath Log marked as Plaintiff's Exhibit #1 to the deposition Stephani
Grace taken on July 15, 2019.
94, All medical records, audit data and screen shots from the on-site computer
inspection at Martin Medical Center.
95. The Plaintiff reserves the right to amend the exhibit list as discovery becomes
known.
CASE NO.: 2019CA000015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via
electronic mail on this qt day of DU ejilev, 2022 to: SEE ATTACHED SERVICE LIST.
Somera & Silva, LLP
One Boca Place
2255 Glades Road, Suite 232W
Boca Raton, FL 33431
Phone: (561) 981-8881
Fax: (561) 981-8887
Primary Email: leadings, SO! ilva.com
Secondary Email: litigation erasilva.com
Attorneys for Plaintiff
By:
Se
PETER J. SOME! A
FBN: 00542 N
PAUL M.S A, M.DXE
FBN: 031920
CASE NO.: 2019CA000015
SERVICE LIST
Geoffrey Fieger, Esq.
Fieger, Fieger, Kenney & Harrington, PC
19390 West Ten Mile Road
Southfield, MI 48075
Primary E-mail: G.Fieger@Fiegerlaw.com
Secondary E-mail: $.Teal@Fiegerlaw.com
(Co-Counsel for Plaintiffs)
Thomas G. Aubin, Esq.
Stearns Weaver Mille Weissler Alhadeff & Sitterson, P.A.
200 East Las Olas Boulevard, Suite 2100
Fort Lauderdale, FL 33301
Primary Email: taubin@stearnsweaver.com
mpodolnick@stearnsweaver.com.
Secondary Email: nrodrigues@stearnsweaver.com
mpetruk@stearnsweaver.com
knetto! @stearnsweaver.com
(Counsels for Defendant, Martin Memorial Medical Center, Inc.
d/b/a Martin Memorial Medical Center)
Adam J. Richardson, Esq.
Bard Rockenbach, Esq.
Burlington & Rockenbach, P.A.
Courthouse Commons/Suite 350
444 West Railroad Avenue
West Palm Beach, FL 33401
Primary Email: ajr@FLAppellateLaw.com
bdr@FLAppellateLaw.com
Secondary Email: fa@FLAppellateLaw.com
(Appellate Counsel for Plaintiffs)
10
Preview
Filing # 163274879 E-Filed 12/19/2022 10:13:26 AM IN THE CIRCUIT COURT OF THE 19™ JUDICIAL CIRCUIT IN AND FOR MARTIN COUNTY, FLORIDA CASE NO.: 2019CA000015 FREDERIC CHARLES GREER, III and MELISSA ANNE GREER, as Husband and Wife, and FREDERIC CHARLES GREER, Il and MELISSA ANNE GREER, individually, Plaintiffs, vs. MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A MARTIN MEDICAL CENTER, a Florida Corporation, KUNAL CHAUDHRY, MD, and CARDIOLOGY ASSOCIATES OF STUART, P.A:, a Florida Profit Corporation, Defendants. / PLAINTIFF’S SEVENTH AMENDED EXHIBIT LIST Plaintiff, FREDERIC CHARLES GREER, III] and MELISSA ANNE GREER, as Husband and Wife, and FREDERIC CHARLES GREER, III and MELISSA ANNE GREER, individually, hereby give notice that they may present the following items as exhibits at the trial of this matter. 1 Any and all medical bills generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, IIL. 2. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III from: Sara Alvarez, LMHC / PSL Counseling. CASE NO.: 2019CA000015 3 Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III from: Gregorio Aquino, Jr., DDS / Tomalty Dental Care. 4 Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III from: Robert Barry, MD / Gabriel Guerrero, MD / Robert Lemieux, MD / Martin Health Physician Group. 5 Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Ibrahim Bassell, EMT / Donovan Bell, EMT / Orlando Fire Department. 6 Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Minda Butler, SLP / Ana Kalinski, PT / Johana Moscoso, OT / Encompass Health Rehabilitation Hospital of Altamonte Springs. 7 Any and all medical records, reports, diagnostic testing, interventions and results generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Kunal Chaudhry, MD / Cardiology Associates of Stuart, PA. 8 Any and all medical records, reports, diagnostic testing, interventions and results generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, Ill, from: Community Home Health Services. 9 Any and all medical records, reports, diagnostic testing, interventions and results generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Cora Physical Therapy. 10. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Michael Demasi, MD / Care Now Urgent Care. 11. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Paul Dreyer, MD / Nephrology Associates of Central Florida. 12. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Robert Eilers, MD. Any and all medical records generated as a result of the medical care and 13. treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: David Fernandez, MD / Hyperbaric Medicine & Wound Care Center. CASE NO.: 2019CA000015 14. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Genesis Medical Laboratory. 15. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Paul Gotkin, DPM / Treasure Coast Podiatry Care. 16. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Robert lannacone, DPM. 17. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: William Kane, MD / Vero Orthopedics Neurology. 18. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: E. Corry Maguire, DPM / Orlando Foot & Ankle Clinic. 19. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: M. Joe Ma, MD, PhD / Peter Pernicone, MD / Michael J. Radt, MD / Seema Shroff, MD, PhD / Charnajeet Singh, MD / Tien-Anh, Tran, MD / Central Florida Pathology Associates, PA. 20. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Javier Marinez, MD / Infectious Disease Consultants. 21. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Andrew Martin, MD / Florida Diabetes & Endocrine Center. 22. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Jerome Obed, MD / Broward Dermatology & Cosmetic Specialists. 23, Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Luis Olivera-Rodriguez, MD / Gustavo Ruiz, MD / Mindful Behavioral Healthcare. 24. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Hal S. Pineless, DO, FACN / NeuroCare Institute of Central Florida. 25. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Karin Sieger, PhD. CASE NO.: 2019CA000015 26. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Shawn Sorensen, PhD. 27. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Vanessa Stavros, BSN, RN, CCM, CLCP / Amerisys. 28. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, Ill, from: St. Lucie Eye Associates. 29. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Nicholas Suite, MD. 30. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, Ill, from: Jeffrey Sutton, MD / Lake Worth Diagnostic Testing Group. 31. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: St. Lucie Cunty Fire District. 32. Any and all medical records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, IIL from: Howard Tee, MD. 33. Any and all hospital records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Florida Hospital Orlando. 34, Any and all hospital records generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: Florida Hospital Transplant Institute. 35. Any and all hospital records, reports, diagnostic tests and results generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, Ill, from Martin Medical Center. 36. Any and all hospital records, reports, diagnostic tests and results generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from: St. Lucie Medical Center. 37. Any and all hospital records, reports, diagnostic tests and results generated as a result of the medical care and treatment of the Plaintiff, FREDERIC CHARLES GREER, III, from Tradition Medical Center. 38. Any and all insurance records of Cigna Insurance Company as the same pertains to the Plaintiff, FREDERIC CHARLES GREER, III. CASE NO.: 2019CA000015 39. Any and all employment records of Palm Beach Sheriff's Office as the same pertains to the Plaintiff, FREDERIC CHARLES GREER, IIL. 40. Any and all pharmacy records of Publix Pharmacy as the same pertains to the Plaintiff, FREDERIC CHARLES GREER, III. 41. Any and all pharmacy records of Walgreens Pharmacy as the same pertains to the Plaintiff, FREDERIC CHARLES GREER, III. 42, Any and all Worker’s Compensation records of USIS as the same pertains to the Plaintiff, FREDERIC CHARLES GREER, III. 43. Cardiac Cath Event/Computer Log, Martin Medical Center. 44, Interventional Services Department Cardiac Result report authored by Kunal Chaudhry M.D. on 9/1/17. 45. 9/1/17 cardiac catheterization diagnostic imaging studies Martin Medical Center. 46. 9/1/17 echocardiogram ultrasounds Martin Medical Center. 47. All records, reports, diagnostic tests and results for FREDERIC CHARLES GREER, III, from St. Lucie County Fire District. 48. Any and all photographs and/or video-tapes as the same pertain to the Plaintiff, FREDERIC CHARLES GREER, III. 49. Pictures of Plaintiff dated July 24, 2018. 50. Pictures of Plaintiff with LVAD from September 2017. 51 Pictures of FREDERIC CHARLES GREER, III six months prior to January 18, 2019. 52 Pictures of Plaintiff after heart transplant take July 2018. 53 Pictures of Plaintiff three months prior to transplant. 54 Pictures of Plaintiff prior to accident. 55 Plaintiffs Facebook posts and photographs. 56 Any and all reports prepared by expert witnesses including, but not limited to, medical reports, rehabilitative, life care plan, and economic reports in this case. CASE NO.: 2019CA000015 57. Life Assistance, Rehab & Medical Management Plan for Home Report prepared by Robert Eilers, MD. 58. Medical Care Cost Summary Report prepared by Ronald Missun, PhD. 59. Loss of Earning Capacity Report prepared by Ronald Missun, PhD. 60. Any and all income tax return as the same pertains to the Plaintiff, FREDERIC CHARLES GREER, III. 6l. Any and all social security earnings statements. 62. Any and all policy and procedure manuals, safety guidelines, etc. for the Defendant herein. 63. Cardiac Cath Lab Policy — Balloon Angioplasty Procedure Patient Room Set-up for Cardiac Cath Procedure. Setting A Sterile Cardiac Cauterization Tray Coronary Stent Procedure Insertion of Intra-Aortic Balloon Catheter Left Heart Catheterization Stemi-Cardiac Alert Cardiac Transfers Decision Tree From Tradition Medical (TMC) Interventional Lab Transcatheter Aortic Valve Replacement Description Through Roles of Cath Lab Personnel Printing Cardiac Cath Reports Surgical Attire Outpatient Admission To Cardiac Cath Holding Room Roles of Cath Lab Personnel Safety Guidelines Utilization of Procedure Rooms During Radiology Special Procedure Down Time Cath Lab Scheduling Guidelines 64. Martin Memorial Medical Center - Medical Staff By-Laws. 65. Marketing Materials for Martin Medical Center and Dr. Chaudhry and his employer. 66. Audit Trail of the electronic medical records for Martin Medical Center for 9/1/2017 for FREDERIC CHARLES GREER, III. CASE NO.: 2019CA000015 67. Any and all records from Social Security Administration as the same pertains to the Plaintiff, FREDERIC CHARLES GREER, III. 68. Any and all contracts involving the Defendant. 69. Frances Langford Heart Center Cardiac Catheterization Laboratory Co-Medical Director Agreement. 70. High Performance Network Leadership Council Services Agreement. 71. Interventional Cardiology Pool Agreement. 72. Martin Memorial Medical Center, Inc. Interventional Cardiology Coverage Agreement. 2. 2011 ACCF/AHA Guideline for Coronary Artery Bypass Graft Surgery. 74. 2011 ACCF/AHA/SCAI Guideline for Percutaneous Coronary Intervention. 75. 2014 AHA/ACC. Guideline for the Management of Patients with Non-ST- Elevation Acute Coronary Syndromes. 76. Any and all medical illustrations, including cardiac catheterization and cardiac echo enlargements and demonstrative aids. 77. Any and all diagrams. 78. Any and all mortality tables. 79 Any and all social security disability reports, forms, applications, medical records. 80. Any and all worker’s compensation reports, evaluations, bills, liens, payments, medical records. 81. Any and all depositions and/or videotape depositions taken in this case and exhibits attached thereto. 82. Any and all interrogatories and documents produced in response to requests for production and discovery requests in this case. 83. Any and all correspondence in this case. 84. Any and all enlargements of medical records diagnostic imaging, including cardiac catheterization and cardiac echo enlargements and demonstrative aids, medical bills, photographs, etc. as the same pertains to this case. CASE NO.: 2019CA000015 85. Records and images received from Martin Medical Center for Frederic Charles Greer, III by Advent Health Orlando f/k/a Florida Hospital Orlando from Records Custodian deposition take on March 20, 2020. 86. Records and images received from Martin Medical Center for Frederic Charles Greer, III by Advent Health Orlando f/k/a Florida Hospital Orlando from Records Custodian deposition take on May 22, 2020. 87. Florida Statute 395.1055 — Hospital Licensing and Regulation — Rules and enforcement. 88. Plaintiff's Exhibit #1 attached to the deposition of David Walkonen taken on July 15, 2019. 89. Plaintiff's Exhibit #2 attached to the deposition of David Walkonen taken on July 15, 2019. 90. Plaintiff's Exhibit #3 attached to the deposition of David Walkonen taken on July 15, 2019. 91. Access log marked as Plaintiffs Exhibit #1 to the deposition Stephani Grace taken on July 15, 2019. 92. Epic Electronic Health Records marked as Plaintiff's Exhibit #1 to the deposition Stephani Grace taken on July 15, 2019. 93. Cardiac Cath Log marked as Plaintiff's Exhibit #1 to the deposition Stephani Grace taken on July 15, 2019. 94, All medical records, audit data and screen shots from the on-site computer inspection at Martin Medical Center. 95. The Plaintiff reserves the right to amend the exhibit list as discovery becomes known. CASE NO.: 2019CA000015 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic mail on this qt day of DU ejilev, 2022 to: SEE ATTACHED SERVICE LIST. Somera & Silva, LLP One Boca Place 2255 Glades Road, Suite 232W Boca Raton, FL 33431 Phone: (561) 981-8881 Fax: (561) 981-8887 Primary Email: leadings, SO! ilva.com Secondary Email: litigation erasilva.com Attorneys for Plaintiff By: Se PETER J. SOME! A FBN: 00542 N PAUL M.S A, M.DXE FBN: 031920 CASE NO.: 2019CA000015 SERVICE LIST Geoffrey Fieger, Esq. Fieger, Fieger, Kenney & Harrington, PC 19390 West Ten Mile Road Southfield, MI 48075 Primary E-mail: G.Fieger@Fiegerlaw.com Secondary E-mail: $.Teal@Fiegerlaw.com (Co-Counsel for Plaintiffs) Thomas G. Aubin, Esq. Stearns Weaver Mille Weissler Alhadeff & Sitterson, P.A. 200 East Las Olas Boulevard, Suite 2100 Fort Lauderdale, FL 33301 Primary Email: taubin@stearnsweaver.com mpodolnick@stearnsweaver.com. Secondary Email: nrodrigues@stearnsweaver.com mpetruk@stearnsweaver.com knetto! @stearnsweaver.com (Counsels for Defendant, Martin Memorial Medical Center, Inc. d/b/a Martin Memorial Medical Center) Adam J. Richardson, Esq. Bard Rockenbach, Esq. Burlington & Rockenbach, P.A. Courthouse Commons/Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Primary Email: ajr@FLAppellateLaw.com bdr@FLAppellateLaw.com Secondary Email: fa@FLAppellateLaw.com (Appellate Counsel for Plaintiffs) 10