Preview
Filing # 130569706 E-Filed 07/13/2021 03:44:00 PM
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, Til and MELISSA ANNE
GREER, individually,
Plaintiffs,
VS.
MARTIN MEMORIAL MEDICAL
CENTER, INC., D/B/A
MARTIN
MEDICAL CENTER, Florida a
Corporation, KUNAL CHAUDHRY,
MD, and CARDIOLOGY ASSOCIATES
OF STUART, P.A., a Florida Profit
Corporation,
Defendants.
/
MOTION FOR AN IN-CAMERA INSPECTION
COMES NOW, the Plaintiffs, FREDERIC CHARLES GREER, III and MELISSA
ANNE GREER, as Husband and Wife, and FREDERIC CHARLES GREER, III and MELISSA
ANNE GREER, individually, by and through undersigned counsel, and hereby files this Motion
for an In-Camera Inspection, and as grounds therefore states as follows:
i That on May 20, 2021, Plaintiffs propounded Fifth Request for Production to
Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A MARTIN MEDICAL to
produce the contact between Epic and Martin Medical Center. See Exhibit “A”.
Electronically Filed Martin 07/13/2021 03:44 PM
CASE NO: 2019-CA-000015
2. On June 21, 2021, Defendant, MARTIN MEMORIAL MEDICAL CENTER,
INC., D/B/A MARTIN MEDICAL filed an objection with a privilege log and redacted large
portions of the Epic License and Support Agreement. See Exhibit “B”.
3 Plaintiff requests and in-camera inspection of the redacted Epic License and
Support Agreement for expert review and analysis.
4 The in-camera inspection is to be completed with the thirty (30) days from the
entry of an order,
WHEREFORE, Plaintiffs, FREDERIC CHARLES GREER, III and MELISSA
ANNE GREER, as Husband and Wife, and FREDERIC CHARLES GREER, III and MELISSA
ANNE GREER, individually, respectfully requests this Honorable Court enter an Order
requiring granted the in-camera inspection.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via
ee
electronic mail on this / 3 day o 4 wy , 2021 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: pleadings@somerasilva.com
Secondary Email: litigation@somerasilva.com
Attorneys for Plai
By:
PETER MERA JR., ESQ
FBN 267
PAU . SILVA, M.D., ESQ.
FBN?:0319820
CASE NO: 2019-CA-000015
SERVICE LIST
Geoffrey Fieger, Esq. Dinah Stein, Esq.
Fieger, Fieger, Kenney & Harrington, PC Hicks, Porter, Ebenfeld & Stein, PA
19390 West Ten Mile Road 799 Brickell Plaza, 9"" Floor
Southfield, MI 48075 Miami, FL 33131
Primary E-mail: G.Fieger@Fiegerlaw.com Primary Emails: dstein@mhickslaw.com
Secondary E-mail: S.Teal@Fiegerlaw.com akozub@mhickslaw.com
(Co-Counsel for Plaintiffs) Secondary Email: eclerk@mhickslaw.com
(Counsel for Defendants, Kunal Chaudhry,
M.D. and Cardiology Associates of Stuart,
Thomas G. Aubin, Esq. P.A)
Stearns Weaver Mille Weissler Alhadeff &
Sitterson, P.A.
200 East Las Olas Boulevard, Suite 2100 Adam J. Richardson, Esq.
Fort Lauderdale, FL 33301 Bard Rockenbach, Esq.
Primary Email: taubin@stearnsweaver.com Burlington & Rockenbach, P.A.
mpodolnick@stearnsweaver.com Courthouse Commons/Suite 350
Secondary Email: 444 West Railroad Avenue
nrodrigues@stearnsweaver.com West Palm Beach, FL 33401
mpetruk@stearnsweaver.com Primary Email: ajr(@FLAppellateLaw.com
knetto@stearnsweaver.com bdr@FLAppellateLaw.com
(Counsels for Defendant, Martin Memorial Secondary Email: fa@FLAppellateLaw.com
Medical Center, Inc. d/b/a Martin Memorial (Appellate Counsel for Plaintiffs)
Medical Center)
Keith J. Puya, Esq.
Hector R. Buigas, Esq.
Law Offices of Keith J. Puya, P.A.
4880 Donald Ross Road, Suite 225
Palm Beach Gardens, FL 33418
Primary Email: eservice@puyalaw.com
Secondary Email: kpuya@puyalaw.com
(Counsels for Defendants, Kunal Chaudhry,
MLD. and Cardiology Associates of Stuart, P.A.)
Filing # 127217959 E-Filed 05/20/2021 02:30:36 PM
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, fll 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.
i
PLAINTIFFS' FIFTH REQUEST FOR PRODUCTION
CHARLES GREER, III and MELISSA ANNE GREER, as
The Plaintiffs, FREDERIC
CHARLES GREER, III and MELISSA ANNE GREER,
Husband and Wife, and FREDERIC
ds this their Request
individually, by and through their undersigned counsel, and hereby propoun
MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A
for Production to Defendant,
CENTER. The Defendant is to respond to said Fifth Request for
MARTIN MEDICAL
Production on or before thirty (30) days of receipt of service.
occurred on
1 The Onsite Computer Inspection as ordered by ordered Judge Sweet
April 21, 2021 at Martin Memorial Medical Center.
HIBIT
A
ce
2 In the transcribed proceedings Stephani Grace, HIM supervisor stated that the
the
version of Dr, Chaudhry’s Interventional Cardiac results missing one sentence describing
wall motion of the left ventricle could not be produced because of the Epic Contract. See
Exhibit “A”.
the electronic medical records of Frederic Greer in existence in
3 Produce
and not the
September 2017 as labeled in Exhibit «G”, the Cardiac result in its final version
chart view version.
4 Produce the contract between Epic and Martin Medical Center for the production
of Protected Health Information of Patients in 2017, including chart view format.
that the
5 Produce the contract between Epic and Martin Medical Center that states
in Exhibit ‘G” is confident ial
print group of the electronic medical records for Frederic Greer
and not part of the electronic medical record of Frederic Greer in 2017.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via
electronic mail on this day of i}, 2021 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: pleadings@somerasilva.com
Secondary Email: litigation@somerasilva.com
7
Attorneys for Plait
By:
PETER MERA JR., ESQ.
FBN: 005 267
PAUL M’ SILVA, M.D., ESQ.
FBN; 0319820
SERVICE LIST
Geoffrey Fieger, Esq. Dinah Stein, Esq.
Fieger, Fieger, Kenney & Harrington, PC Hicks, Porter, Ebenfeld & Stein, PA
19390 West Ten Mile Road 799 Brickell Plaza, 9" Floor
Southfield, MI 48075 Miami, FL 33131
Primary E-mail: G.Fieger@Fiegerlaw.com Primary Emails: dstein@mhickslaw.com
Secondary E-mail: S.Teal@Fiegerlaw.com akozub@mhickslaw.com
(Co-Counsel for Plaintiffs) Secondary Email: eclerk@mhickslaw.com
(Counsel for Defendants, Kunal Chaudhry,
M.D. and Cardiology Associates of Stuart,
Thomas G. Aubin, Esq. PA)
Stearns Weaver Mille Weissler Alhadeff &
Sitterson, P.A.
200 East Las Olas Boulevard, Suite 2100 Adam. J. Richardson, Esq.
Fort Lauderdale, FL 33301 Bard Rockenbach, Esq.
Primary Email: taubin@stearnsweaver.com Burlington & Rockenbach, P.A.
mpodolnick@stearnsweaver.com Courthouse Commons/Suite 350
Secondary Email: nrodrigues@stearnsweaver.com 444 West Railroad Avenue
mpetruk@stearnsweaver.com West Palm Beach, FL 33401
knetto@stearnsweaver.com Primary Email: ajr@FLAppellateLaw.com
(Counsels for Defendant, Martin Memorial bdr@FLAppellateLaw.com
Medical Center, Inc. d/b/a Martin Secondary Email:
Memorial Medical Center) fa@FLAppellateLaw.com
(Appellate Counsel for Plaintiffs)
Keith J. Puya, Esq.
Hector R. Buigas, Esq.
Law Offices of Keith J. Puya, P.A.
4880 Donald Ross Road, Suite 225
Palm Beach Gardens, FL 33418
Primary Email: eservice@puyalaw.com
Secondary Email: kpuya@puyalaw.com
(Counsels for Defendants, Kunal Chaudhry,
M.D. and Cardiology Associates of Stuart,
P.A)
PROCEEDINGS April 21, 202 1
GREER V MMMC. 3
MR. GARRETT: So in chart rearview, like this
is printed, there's two sentences there and here ig one.
Can you pull it up like this that has the one sentence
in it?
MS. GRACE: This is what we have. This is
what I can pull up. I can't pull up stuff from -- I
can't pull up something from 2017.
MR. SILVA: I just want to be clear for the
record, Exhibit G, which has one sentence, cannot be
10 pulled up today. Exhibit F, that has two sentences, can
11 be.
12 MR. GARRETT: Do you have any auditing data?
13 MS. KURISH: That's because the print group
14 was fixed between both of those exhibits so that's why
5) we can pull it up today.
16 MS RANDENBURG : Jamie, what if we put the
17 broken print group back in there and then print?
18 MS GRACE: I mean, that was produced from
19 chart review A caregiver printed it out the wrong way.
20 MS BRANDENBURG : Right.
21 MS GRACE: They're not supposed to be
22 printing it out that way, anyway, so.
23 MS. BRANDENBURG: So in sup, I wonder if we
24 put the broken print group into the chart review report
25 and then show them that it was broken back then.
Z ESQUIRE
ozposiTion soLuTIONS,
800.211.DEPO (3376)
EsquireSolutions.com
EXHIBIT
PROCEEDINGS April
21, 2021
GREER V MMMC 4
Because --
MR. AUBIN: Give us a minute and we'll see if
there's a way to do that.
MR. SOMERA: Take a two-minute bathroom break.
(A recess was taken.
MR. GARRETT: Before we went on our little
break, you said, I guess there was some discussion to
look up something or something you wanted to maybe show
us.
10 MS. GRACE: The answer is, can you ask me what
11 your question is again?
ali MR. GARRETT: I asked if there's any way to
13 see the print group that would show why a sentence
14 exists or doesn't exist in the printed record?
15 MS. GRACE: The answer is no. Unfortunately,
16 because of our Epic agreement, those print groups are
7 confidential so we are not able to share that
18 information with you.
9) MR. SILVA: Guess what. For the record, put
20 on the record that the representatives at the hospital
21 OO —_—_———_-_, print
22 group. Is that what it's called?
23 MR. GARRETT: Yes.
24 MR. SILVA: The print group for the cardiac
25 cath report authored by Dr. Kunal Chaudhry on
@ ESQUIRE DEPOSITION SOLUTIONS
800.211.DEPO (3376)
EsquireSolutions.com
PROCEEDINGS April
21, 2021
GREER V MMMC 35
September lst, 2017.
That's it.
MR. AUBIN: Okay. So we have 11 exhibits,
screenshots that were taken.
MS GRACE: Yes.
MR AUBIN: Is that it?
MR SILVA: Yep.
MR AUBIN: All you guys wanted.
MR SILVA: Yep.
10 And you're going to have those to us within
11 seven days?
12 MR. AUBIN: Whatever the order is, yeah. I
ars) think it's seven days, Paul.
14 MR. SILVA: All right. Okay. Thank you.
15 MR. AUBIN: Okay, thanks.
16 We'll get a copy of the transcript,
Gy Ms. Reporter.
18 MR. SILVA: We're going to order. Big hard
19 copy, mini hard copy, and an E-Tran to depos, D-E-P-O-S,
20 at somerasilva dot com.
21 (The On-site Hospital Computer Inspection was
22 concluded 1:13 p.m.)
23
24
25
Z ESQUIRE
DEPOSITION SOLUTIONS
800.211.DEPO (3376)
EsquireSolutions.com
a
“Cardiology Associate POTSmodemt (15792) 10/12/2018 02:53:34 PM ~0400
iChart)[Fredetick Greer)[89940]
a
rect, Frédetick:(MR # Me 90 fa 6) EXHIBIT
ssa eB,=
3
MARTIN HEALTH. SYSTEM
igiok (4
Interventional Services Department
MC CARDIAC CATH
9,0 Box 9010
Stuart, Florida 34995 Pte
772-223-5919
Cardiac Result
C
Name: MEN. DOW
Greer, Frederick M590736 2/20/1965
Pracedure(s) Performed: oACEOSSION Exam Date
Cardiac catheterization 006774699 09/04/2027
Perica tocentesis 006775051 09701/2017
‘Sex! “Mate Patient Class. Inpatient
Ord Prov and CC Recipients: Reasan for Exam: STEMI
Kunal Chaudhry STEMI
KunalChaudhry
Progedures Performed.
Ihipella Insertion
Pe neds: céronary tntervention
ert atentos!
Cardiac Alert
LAC/CORONARIESIGRAFTS WIWO LV GRAM
Physiciahs
anal Physic ns Retening Physician Cane sonzing PS
Kunsl Chauajry 140 (Primary)
Indications |
_ NBTEMI {none8T slevated myecardial infarction)(*) (21.4 (IGD-40-CM)]
‘Cardiogganic shack (*){R57.0.(GD-10-CM)]
Pe ee rocedure Diagnosis
STEMI ©
Gatdiageiile Shock
Gitritead History hyperlipidemia who
Tha patients @ $2-year-old mate with past mental history signidyificant for insulin-dependant diabetes andwhich had beer’ ongoing for
‘piosented ta the emosgancy food With complaints along with rest chest discomfort
of savers jspneaa traonin
4days, ‘His trltlal Gardiaa biomarkers wore: itkédly. élavated with consistent with | graater than 20: His electrocardisgrant
d&mnor at dyidened af Cwaves goroas 3 infacolaforal leads He was brought ahwith.inferior poateriat taleral mygeardial infarction
yhicty torteinats sod likely 4 days priorto presentation, the diaghosls-of a Aon-ST eisvation
miyscard ln ids ioe ‘origaing- symptoms in the setting of cardiogeitic shock
Piocedure detal! sheath waa inserted info the right radial artery
A2% " IidocBING Bolution wap used to anesthelize the right wrist, and a 6/6the Fronch left main and multiple angiographic views were
without Issue. ‘A.5 FrenchTI dlagnostic catheter was used to engage
‘oblalrigel: The sane enthelér was used LVto etgage the right coronary artery, at ind mul Riple angiographic views wore’ ovtalned. A SF
Pigtal ‘Gathioler Was Used to transduce hemodynamics. Lett ventriculograpt fy was performed with the sare catheter,
Fae) /Adatls cardiac Gathalarization, a 6 French XB LAD 3.8 guide cathetar was used to1 ‘0 engoge the lef main ‘obeofsty
attempt {0 cfoss the’ proximallett
‘Thy:patian (Waa-antlcoaquiated with Intcavenous bivalirudin. A run-through wire andwas theused (kel itsood thatOngolrig
the infarction. occuirad # days"?
‘eirouinns 5X Jeston’ but, {his was Abt possible occlusion
givén.the longevity ofthetheintorolataral laads. He did hi ave aymintoms which
Age pled patlent’s slettrotargiogtam jahlected Q waves derose, 150 wire to cross the lesion and. was’ fete e
Br ar-attenint at latervention. A:Corsair cathater was used along with & pilot
reel prea # M590736) ee by Karen Lara [KLARA] at oI? 10:42 AM
7 —
(Page 14 of 91]
1G
‘ -0400
02:54:45 PM
‘cardiology Associate POTSmodemt _ 10/12/2018
:Chart][Frederick Greer](89940} a
—— ~ — -
Greer, Frederick (MR # MS90736)
distal aortion of the marginal and the pilot 180mmwire wos
distal portion of the OM1, The Coi yrsalr catheter was then passed inte thecircumflex
exchanged for a long run-through wire. The proximal portion of the left was dilated several times with a 2.5
compltant balloon followed by a 5. .0 men compliant balloan with no flow in the vessel des: pile this..A surgical consultation was
at this time {or coronary bypase gral iting given
obtained at ne bedside and the pal tient was fol felt to be a suitable candidate balloon was also usad to predilate the proximal
‘ongoing infarction in @ passible nonvlable. distribution: The 2.5 mm compliant but with evidence of frank
portlan of the OM: Sul ibsequent angiogtaph y revealed improvement in flow In. the circumflex distrtoution and
parforation of the coronary veaeal in ti na mid sagment of the OMI. The patlent' 's bload prassure subsequently dropped improvement in
intravenous bivalirudin was discontinued. The p: nt received multiple boluses of Neo-Synephrine with same
pericardiocentesis tray was opened and multiple al uampis ware Used to perform pericard locentesis
blood pressure, An emergency from the chest wall to the actual pecicardi ium. Despite use acke of an ultasound, we ware unsuccesstul
unsuccessfully given the depth ty, At this time, [had Dr. Crouet h from cardiothor surgary performed a pericardial
in entering the pericardium percutangoust ent in hemadynamt kes and removal of bloady fluld, The patient was also intubated
window in the cath tab with successful Irprovem time and nacaivod paralytic and sedation for the procadur e, Repeat angiagraphy
for alrway protection during this period of he pericardiu m, The pallent however developed
demonstrat ad closure of tha proximal loft circu mttax with no further bleeding into U
worsening cardiogenic shock which was present initially as hi is opening left ventricular end: -diastolic prosaura was 40 mmHg ia the
was made to obi jain left common femoral arterial access and the
gating of multivessel coronary di fisease. Al this lime, the decision sheath, Successt ful and uncomplicated placement of
6 French sheath which was inse’ ited with serial dilatations up to a 14 tFi rench In hemodynamnica. Ouring this period of me, {he patient
an Inpalla CP davios w /as than performad with significant improvemen and medications as outlines by nursing. After
did sustain 2 episodes of a PEA arrest which required CPR wi ith chest compressions amics signifieanty improved but he was
placement of the dovica, the patient started to improve oll tnioal ily. His overall hemodyn arterial were was then obtained to
malntainad on high dose-norepinaphrine and phenylephrine. Right common femoral accessaccess
venous sites was obtained and exchanged
roavaluate the coronary arteries which were unch: angad. Left common femoral care unit. The case was discussed in detail
for a tripl io lumen cathetar which was left in were placa for transfer ta the cardiac Intensive
with the patient's wi if and family members aware of his critleat condition.
During this procedure, Or, Chaudhry adrninister ed moderate consciaus stdation using vers edjal saturation and fentanyl, Or, Chaudhry was
, and cespiratory rate by an
assisted in monitorin g the patient's (evel of cons« clousness, blaad pressure, heartrate, arter\
Independent, critical care nur: ae as documented inthe chart.to face Pre-and post-assessment and monitoring until was performed. Dr,
time aflar aciministration of sedation Dr. Chaudhry exited (he
Chaudhry documented intraservice time (cent Wnuaus face
room) was 279 minutes.
Contrast
Visipaque 320 was used during the procedure, total contrast used was 200 mi.
Left Heart
Left Ventricia 8%, The EOP Is calculated to be 44,
LV end diastolic pr essure {s sdveroly elavated. The election fraction [s calculated to ba t
Wail Motion
Aortic
: ag efa
& Syay
Mitent
hy
a eha
Se
Ste aay
aa
oy
u ios
Ae aa ce
i
g sogments with LV
Akinesia of 1 the mid infoctor wall with oversil severe hypokinesis of the remainin
ejection fraction estimate d at 15%.
EB Hypckinesis @ rxinesis E® ovskinesie BD Aveurysmat
@Dvormar
Coronary Findings
Dominance: Right
Left Main ly normal, The vessel originates from the left coronary
The vessel was visualized by angiography, is large and is angiographical
simis,
Lett Anterlor Descending
he
ie a .
[KLARA] at 9/7/17 10:42 AM Page 2 of 6
Greer, Frederick (MR # M590736) Printed by Karen Lara
[Page15 of 91)
Cardiology Associate POTSmodem! _ 10/12/2018 02:55:57 PM -0400
‘Chart}[Fredevick Greer][89940] =
Se
Greer, Frederick (MR 4 M590736)
‘The vessal is moderate in size, The vessel is moderately calcified.
+ Prox LAD lesion, 30% stenosis.
+ Mid LAD lesion, 60% stenosis,
+ Dist LAD fasion, 70% stenosis.
Loft Cireumttox
‘The vossatis moderate in size.
+ Prox Cx laston, 100% stenosis, Culprit lesion. The tesion is C = 20mm or grsater. The lasion was nat previously treated.
+ PCI: Lesion tength: 30 mm. The guidewire cros sed lesion, Angtoplasty alone was performed, There is no pre-Interventional
antegrade distal fw (FIM(O). There is no post interventional aniagrade distal flaw (TIMI 0). The intervention was
unsuccessful, No reflow due to non viable myocardium ‘Al this lasion, a perforation of the vessel occurred. Pressure
IVUS was not pe “formed on the lesion. No optleal coherence tomography
WwirelFFR was not performed on the lesion.wasn't
(OCT) was performed, The intervention successful,
+ There is 2 100% residual stenosis post intervention,
Right Goronary Artory coronary sinus. The
‘The vessel was visualized by angiography and is moderate in size, The ves: sel originates from the right
vaasel ig maderately calcifia
+ Mid RCA lesion, 95% stenosis,
+ Dist RCA+T lesion, 60% stenosis.
+ Dist RCA-2 fasion, 70% stenosis.
Condition
Catdiac Oulput Sysieinie Arterial Eaumarad OF
Condition RR BSA Memaglobin KO
106 bern 2.42 m2 3.1 gfdt. 133 321.88
02 REST
Pressures O2 REST Blood Cas
Diastohe ROP Means Awave Wave §
Data Tine Systotic
AO 6:55 AM 413 mmHg 84 mmr 96 mmHg
7:10 AM 107 mmHg 30 malig 91 mmtg
7:29 AM 100. mmHg 74 ramHg 83 mmHg
7:52 AM 62 mmiig 48 mniig 62 mmHg
AN 63 mmHg 50 mmiig 55 mmHg
8:02 AM 132 mmHg, 88 mmHg 102 mrtg
8:07 AM 126 mmbig 94 mmitg 105 mmbig
B10 AM 124 mmb4g 9t mmitg 102 mmHg
B12 AM 145 mmtig 85 mma 96 mtg
8:20 AM 94 mmHg 88 mmHg 78 mmeg
8:23 AM 17 mmHg 99. mmHg 107 mmtig
8:24 AM 79 mmHg 87 mmHg 74 mmHg
8:27 AM 125 mmHg 116 mmitg 121 mmHg
8:42 AM a7 mmtg, 81 mmHg 64 mmHg
6:42 AM 82 mmHg 47 mmHg 65 mmHg
8:45 AM 122 mmHg 70 mmHg 8a mmHg,
8:47 AM 101 mmHg 87 mrtg 73 mmHa
6:48 AM 133 mmHg 77 mmHg 97 mmHg
8:55 AM 105 mmg 62 mmHg 77 mmHg
0:05 AM - 106 mmHg 84 mratig 78 mmHg
8:10 AM 70 mmHg 38 mentig 60 mmHg
9:12 AM 69 mmHg 44 mmHg 51 mmHg
Ww 7:00 AM 124 mmHg, +6. mmHg 44 mmHg
AOp “7:60 AM 419. mmHg 48 mtg 6 mmHg
LVp 7:00 AM 424 mmHg 47 meng 99 mmHg
Blood Oximetry 9/1/17 0639--9/1/17 1057 SpO2
Bale/Time Pulse Rasp Be
20 128/86 92%
NOAM. O8: 34. 87 112/64 Ss
OgiOttT 10:16:32 103 ae
[KLARA] at 9/7/17 10:42 AM Page 3
Greer, Frederick (MR # M590736) Printed by Karen Lara
{Page
16 of 91}
‘
(18/92) 10/12/2018 02:56:57 PM -0400
Card io logy Associate POTSmodem)
Chart)[Brederick Grees(89540) _— —
= —— a
. Greer, Frederick (MR # MS90736)
O9/O117 10:25:08 102 18 494770
-“Tmpella:insertion
iri Insertion The parformance favel was PO. The Impella was nat reposivonad, Gardize
er Was Insorted Io the tal ft famoral artory.
“gutput wae 3 (rnin,
} Pericardiscentesis
Poiteardiush
apical and parastamal ap: proach with flyare and with uitrasoun d, Unguccesstut attempt at
Pericandioceit jesis performed byfromthe cltast Wall {6 poriodrdlum , Bodside pericardia l window performe d by Dr, Crouch,
pericardiocante: sis given-dapt h
Suri
Génclusio 4 days old in the setting of Q waves across the
Gedliision of the proximal left circumflex artery which is likely angioplasty with no
O flow,:100%,ocelusion, culprit vess: Jal) status post balloon ‘dial tamipangde reqititing
Preview
Filing # 130569706 E-Filed 07/13/2021 03:44:00 PM 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, Til and MELISSA ANNE GREER, individually, Plaintiffs, VS. MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A MARTIN MEDICAL CENTER, Florida a Corporation, KUNAL CHAUDHRY, MD, and CARDIOLOGY ASSOCIATES OF STUART, P.A., a Florida Profit Corporation, Defendants. / MOTION FOR AN IN-CAMERA INSPECTION COMES NOW, the Plaintiffs, FREDERIC CHARLES GREER, III and MELISSA ANNE GREER, as Husband and Wife, and FREDERIC CHARLES GREER, III and MELISSA ANNE GREER, individually, by and through undersigned counsel, and hereby files this Motion for an In-Camera Inspection, and as grounds therefore states as follows: i That on May 20, 2021, Plaintiffs propounded Fifth Request for Production to Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A MARTIN MEDICAL to produce the contact between Epic and Martin Medical Center. See Exhibit “A”. Electronically Filed Martin 07/13/2021 03:44 PM CASE NO: 2019-CA-000015 2. On June 21, 2021, Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A MARTIN MEDICAL filed an objection with a privilege log and redacted large portions of the Epic License and Support Agreement. See Exhibit “B”. 3 Plaintiff requests and in-camera inspection of the redacted Epic License and Support Agreement for expert review and analysis. 4 The in-camera inspection is to be completed with the thirty (30) days from the entry of an order, WHEREFORE, Plaintiffs, FREDERIC CHARLES GREER, III and MELISSA ANNE GREER, as Husband and Wife, and FREDERIC CHARLES GREER, III and MELISSA ANNE GREER, individually, respectfully requests this Honorable Court enter an Order requiring granted the in-camera inspection. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via ee electronic mail on this / 3 day o 4 wy , 2021 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: pleadings@somerasilva.com Secondary Email: litigation@somerasilva.com Attorneys for Plai By: PETER MERA JR., ESQ FBN 267 PAU . SILVA, M.D., ESQ. FBN?:0319820 CASE NO: 2019-CA-000015 SERVICE LIST Geoffrey Fieger, Esq. Dinah Stein, Esq. Fieger, Fieger, Kenney & Harrington, PC Hicks, Porter, Ebenfeld & Stein, PA 19390 West Ten Mile Road 799 Brickell Plaza, 9"" Floor Southfield, MI 48075 Miami, FL 33131 Primary E-mail: G.Fieger@Fiegerlaw.com Primary Emails: dstein@mhickslaw.com Secondary E-mail: S.Teal@Fiegerlaw.com akozub@mhickslaw.com (Co-Counsel for Plaintiffs) Secondary Email: eclerk@mhickslaw.com (Counsel for Defendants, Kunal Chaudhry, M.D. and Cardiology Associates of Stuart, Thomas G. Aubin, Esq. P.A) Stearns Weaver Mille Weissler Alhadeff & Sitterson, P.A. 200 East Las Olas Boulevard, Suite 2100 Adam J. Richardson, Esq. Fort Lauderdale, FL 33301 Bard Rockenbach, Esq. Primary Email: taubin@stearnsweaver.com Burlington & Rockenbach, P.A. mpodolnick@stearnsweaver.com Courthouse Commons/Suite 350 Secondary Email: 444 West Railroad Avenue nrodrigues@stearnsweaver.com West Palm Beach, FL 33401 mpetruk@stearnsweaver.com Primary Email: ajr(@FLAppellateLaw.com knetto@stearnsweaver.com bdr@FLAppellateLaw.com (Counsels for Defendant, Martin Memorial Secondary Email: fa@FLAppellateLaw.com Medical Center, Inc. d/b/a Martin Memorial (Appellate Counsel for Plaintiffs) Medical Center) Keith J. Puya, Esq. Hector R. Buigas, Esq. Law Offices of Keith J. Puya, P.A. 4880 Donald Ross Road, Suite 225 Palm Beach Gardens, FL 33418 Primary Email: eservice@puyalaw.com Secondary Email: kpuya@puyalaw.com (Counsels for Defendants, Kunal Chaudhry, MLD. and Cardiology Associates of Stuart, P.A.) Filing # 127217959 E-Filed 05/20/2021 02:30:36 PM 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, fll 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. i PLAINTIFFS' FIFTH REQUEST FOR PRODUCTION CHARLES GREER, III and MELISSA ANNE GREER, as The Plaintiffs, FREDERIC CHARLES GREER, III and MELISSA ANNE GREER, Husband and Wife, and FREDERIC ds this their Request individually, by and through their undersigned counsel, and hereby propoun MARTIN MEMORIAL MEDICAL CENTER, INC., D/B/A for Production to Defendant, CENTER. The Defendant is to respond to said Fifth Request for MARTIN MEDICAL Production on or before thirty (30) days of receipt of service. occurred on 1 The Onsite Computer Inspection as ordered by ordered Judge Sweet April 21, 2021 at Martin Memorial Medical Center. HIBIT A ce 2 In the transcribed proceedings Stephani Grace, HIM supervisor stated that the the version of Dr, Chaudhry’s Interventional Cardiac results missing one sentence describing wall motion of the left ventricle could not be produced because of the Epic Contract. See Exhibit “A”. the electronic medical records of Frederic Greer in existence in 3 Produce and not the September 2017 as labeled in Exhibit «G”, the Cardiac result in its final version chart view version. 4 Produce the contract between Epic and Martin Medical Center for the production of Protected Health Information of Patients in 2017, including chart view format. that the 5 Produce the contract between Epic and Martin Medical Center that states in Exhibit ‘G” is confident ial print group of the electronic medical records for Frederic Greer and not part of the electronic medical record of Frederic Greer in 2017. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic mail on this day of i}, 2021 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: pleadings@somerasilva.com Secondary Email: litigation@somerasilva.com 7 Attorneys for Plait By: PETER MERA JR., ESQ. FBN: 005 267 PAUL M’ SILVA, M.D., ESQ. FBN; 0319820 SERVICE LIST Geoffrey Fieger, Esq. Dinah Stein, Esq. Fieger, Fieger, Kenney & Harrington, PC Hicks, Porter, Ebenfeld & Stein, PA 19390 West Ten Mile Road 799 Brickell Plaza, 9" Floor Southfield, MI 48075 Miami, FL 33131 Primary E-mail: G.Fieger@Fiegerlaw.com Primary Emails: dstein@mhickslaw.com Secondary E-mail: S.Teal@Fiegerlaw.com akozub@mhickslaw.com (Co-Counsel for Plaintiffs) Secondary Email: eclerk@mhickslaw.com (Counsel for Defendants, Kunal Chaudhry, M.D. and Cardiology Associates of Stuart, Thomas G. Aubin, Esq. PA) Stearns Weaver Mille Weissler Alhadeff & Sitterson, P.A. 200 East Las Olas Boulevard, Suite 2100 Adam. J. Richardson, Esq. Fort Lauderdale, FL 33301 Bard Rockenbach, Esq. Primary Email: taubin@stearnsweaver.com Burlington & Rockenbach, P.A. mpodolnick@stearnsweaver.com Courthouse Commons/Suite 350 Secondary Email: nrodrigues@stearnsweaver.com 444 West Railroad Avenue mpetruk@stearnsweaver.com West Palm Beach, FL 33401 knetto@stearnsweaver.com Primary Email: ajr@FLAppellateLaw.com (Counsels for Defendant, Martin Memorial bdr@FLAppellateLaw.com Medical Center, Inc. d/b/a Martin Secondary Email: Memorial Medical Center) fa@FLAppellateLaw.com (Appellate Counsel for Plaintiffs) Keith J. Puya, Esq. Hector R. Buigas, Esq. Law Offices of Keith J. Puya, P.A. 4880 Donald Ross Road, Suite 225 Palm Beach Gardens, FL 33418 Primary Email: eservice@puyalaw.com Secondary Email: kpuya@puyalaw.com (Counsels for Defendants, Kunal Chaudhry, M.D. and Cardiology Associates of Stuart, P.A) PROCEEDINGS April 21, 202 1 GREER V MMMC. 3 MR. GARRETT: So in chart rearview, like this is printed, there's two sentences there and here ig one. Can you pull it up like this that has the one sentence in it? MS. GRACE: This is what we have. This is what I can pull up. I can't pull up stuff from -- I can't pull up something from 2017. MR. SILVA: I just want to be clear for the record, Exhibit G, which has one sentence, cannot be 10 pulled up today. Exhibit F, that has two sentences, can 11 be. 12 MR. GARRETT: Do you have any auditing data? 13 MS. KURISH: That's because the print group 14 was fixed between both of those exhibits so that's why 5) we can pull it up today. 16 MS RANDENBURG : Jamie, what if we put the 17 broken print group back in there and then print? 18 MS GRACE: I mean, that was produced from 19 chart review A caregiver printed it out the wrong way. 20 MS BRANDENBURG : Right. 21 MS GRACE: They're not supposed to be 22 printing it out that way, anyway, so. 23 MS. BRANDENBURG: So in sup, I wonder if we 24 put the broken print group into the chart review report 25 and then show them that it was broken back then. Z ESQUIRE ozposiTion soLuTIONS, 800.211.DEPO (3376) EsquireSolutions.com EXHIBIT PROCEEDINGS April 21, 2021 GREER V MMMC 4 Because -- MR. AUBIN: Give us a minute and we'll see if there's a way to do that. MR. SOMERA: Take a two-minute bathroom break. (A recess was taken. MR. GARRETT: Before we went on our little break, you said, I guess there was some discussion to look up something or something you wanted to maybe show us. 10 MS. GRACE: The answer is, can you ask me what 11 your question is again? ali MR. GARRETT: I asked if there's any way to 13 see the print group that would show why a sentence 14 exists or doesn't exist in the printed record? 15 MS. GRACE: The answer is no. Unfortunately, 16 because of our Epic agreement, those print groups are 7 confidential so we are not able to share that 18 information with you. 9) MR. SILVA: Guess what. For the record, put 20 on the record that the representatives at the hospital 21 OO —_—_———_-_, print 22 group. Is that what it's called? 23 MR. GARRETT: Yes. 24 MR. SILVA: The print group for the cardiac 25 cath report authored by Dr. Kunal Chaudhry on @ ESQUIRE DEPOSITION SOLUTIONS 800.211.DEPO (3376) EsquireSolutions.com PROCEEDINGS April 21, 2021 GREER V MMMC 35 September lst, 2017. That's it. MR. AUBIN: Okay. So we have 11 exhibits, screenshots that were taken. MS GRACE: Yes. MR AUBIN: Is that it? MR SILVA: Yep. MR AUBIN: All you guys wanted. MR SILVA: Yep. 10 And you're going to have those to us within 11 seven days? 12 MR. AUBIN: Whatever the order is, yeah. I ars) think it's seven days, Paul. 14 MR. SILVA: All right. Okay. Thank you. 15 MR. AUBIN: Okay, thanks. 16 We'll get a copy of the transcript, Gy Ms. Reporter. 18 MR. SILVA: We're going to order. Big hard 19 copy, mini hard copy, and an E-Tran to depos, D-E-P-O-S, 20 at somerasilva dot com. 21 (The On-site Hospital Computer Inspection was 22 concluded 1:13 p.m.) 23 24 25 Z ESQUIRE DEPOSITION SOLUTIONS 800.211.DEPO (3376) EsquireSolutions.com a “Cardiology Associate POTSmodemt (15792) 10/12/2018 02:53:34 PM ~0400 iChart)[Fredetick Greer)[89940] a rect, Frédetick:(MR # Me 90 fa 6) EXHIBIT ssa eB,= 3 MARTIN HEALTH. SYSTEM igiok (4 Interventional Services Department MC CARDIAC CATH 9,0 Box 9010 Stuart, Florida 34995 Pte 772-223-5919 Cardiac Result C Name: MEN. DOW Greer, Frederick M590736 2/20/1965 Pracedure(s) Performed: oACEOSSION Exam Date Cardiac catheterization 006774699 09/04/2027 Perica tocentesis 006775051 09701/2017 ‘Sex! “Mate Patient Class. Inpatient Ord Prov and CC Recipients: Reasan for Exam: STEMI Kunal Chaudhry STEMI KunalChaudhry Progedures Performed. Ihipella Insertion Pe neds: céronary tntervention ert atentos! Cardiac Alert LAC/CORONARIESIGRAFTS WIWO LV GRAM Physiciahs anal Physic ns Retening Physician Cane sonzing PS Kunsl Chauajry 140 (Primary) Indications | _ NBTEMI {none8T slevated myecardial infarction)(*) (21.4 (IGD-40-CM)] ‘Cardiogganic shack (*){R57.0.(GD-10-CM)] Pe ee rocedure Diagnosis STEMI © Gatdiageiile Shock Gitritead History hyperlipidemia who Tha patients @ $2-year-old mate with past mental history signidyificant for insulin-dependant diabetes andwhich had beer’ ongoing for ‘piosented ta the emosgancy food With complaints along with rest chest discomfort of savers jspneaa traonin 4days, ‘His trltlal Gardiaa biomarkers wore: itkédly. élavated with consistent with | graater than 20: His electrocardisgrant d&mnor at dyidened af Cwaves goroas 3 infacolaforal leads He was brought ahwith.inferior poateriat taleral mygeardial infarction yhicty torteinats sod likely 4 days priorto presentation, the diaghosls-of a Aon-ST eisvation miyscard ln ids ioe ‘origaing- symptoms in the setting of cardiogeitic shock Piocedure detal! sheath waa inserted info the right radial artery A2% " IidocBING Bolution wap used to anesthelize the right wrist, and a 6/6the Fronch left main and multiple angiographic views were without Issue. ‘A.5 FrenchTI dlagnostic catheter was used to engage ‘oblalrigel: The sane enthelér was used LVto etgage the right coronary artery, at ind mul Riple angiographic views wore’ ovtalned. A SF Pigtal ‘Gathioler Was Used to transduce hemodynamics. Lett ventriculograpt fy was performed with the sare catheter, Fae) /Adatls cardiac Gathalarization, a 6 French XB LAD 3.8 guide cathetar was used to1 ‘0 engoge the lef main ‘obeofsty attempt {0 cfoss the’ proximallett ‘Thy:patian (Waa-antlcoaquiated with Intcavenous bivalirudin. A run-through wire andwas theused (kel itsood thatOngolrig the infarction. occuirad # days"? ‘eirouinns 5X Jeston’ but, {his was Abt possible occlusion givén.the longevity ofthetheintorolataral laads. He did hi ave aymintoms which Age pled patlent’s slettrotargiogtam jahlected Q waves derose, 150 wire to cross the lesion and. was’ fete e Br ar-attenint at latervention. A:Corsair cathater was used along with & pilot reel prea # M590736) ee by Karen Lara [KLARA] at oI? 10:42 AM 7 — (Page 14 of 91] 1G ‘ -0400 02:54:45 PM ‘cardiology Associate POTSmodemt _ 10/12/2018 :Chart][Frederick Greer](89940} a —— ~ — - Greer, Frederick (MR # MS90736) distal aortion of the marginal and the pilot 180mmwire wos distal portion of the OM1, The Coi yrsalr catheter was then passed inte thecircumflex exchanged for a long run-through wire. The proximal portion of the left was dilated several times with a 2.5 compltant balloon followed by a 5. .0 men compliant balloan with no flow in the vessel des: pile this..A surgical consultation was at this time {or coronary bypase gral iting given obtained at ne bedside and the pal tient was fol felt to be a suitable candidate balloon was also usad to predilate the proximal ‘ongoing infarction in @ passible nonvlable. distribution: The 2.5 mm compliant but with evidence of frank portlan of the OM: Sul ibsequent angiogtaph y revealed improvement in flow In. the circumflex distrtoution and parforation of the coronary veaeal in ti na mid sagment of the OMI. The patlent' 's bload prassure subsequently dropped improvement in intravenous bivalirudin was discontinued. The p: nt received multiple boluses of Neo-Synephrine with same pericardiocentesis tray was opened and multiple al uampis ware Used to perform pericard locentesis blood pressure, An emergency from the chest wall to the actual pecicardi ium. Despite use acke of an ultasound, we ware unsuccesstul unsuccessfully given the depth ty, At this time, [had Dr. Crouet h from cardiothor surgary performed a pericardial in entering the pericardium percutangoust ent in hemadynamt kes and removal of bloady fluld, The patient was also intubated window in the cath tab with successful Irprovem time and nacaivod paralytic and sedation for the procadur e, Repeat angiagraphy for alrway protection during this period of he pericardiu m, The pallent however developed demonstrat ad closure of tha proximal loft circu mttax with no further bleeding into U worsening cardiogenic shock which was present initially as hi is opening left ventricular end: -diastolic prosaura was 40 mmHg ia the was made to obi jain left common femoral arterial access and the gating of multivessel coronary di fisease. Al this lime, the decision sheath, Successt ful and uncomplicated placement of 6 French sheath which was inse’ ited with serial dilatations up to a 14 tFi rench In hemodynamnica. Ouring this period of me, {he patient an Inpalla CP davios w /as than performad with significant improvemen and medications as outlines by nursing. After did sustain 2 episodes of a PEA arrest which required CPR wi ith chest compressions amics signifieanty improved but he was placement of the dovica, the patient started to improve oll tnioal ily. His overall hemodyn arterial were was then obtained to malntainad on high dose-norepinaphrine and phenylephrine. Right common femoral accessaccess venous sites was obtained and exchanged roavaluate the coronary arteries which were unch: angad. Left common femoral care unit. The case was discussed in detail for a tripl io lumen cathetar which was left in were placa for transfer ta the cardiac Intensive with the patient's wi if and family members aware of his critleat condition. During this procedure, Or, Chaudhry adrninister ed moderate consciaus stdation using vers edjal saturation and fentanyl, Or, Chaudhry was , and cespiratory rate by an assisted in monitorin g the patient's (evel of cons« clousness, blaad pressure, heartrate, arter\ Independent, critical care nur: ae as documented inthe chart.to face Pre-and post-assessment and monitoring until was performed. Dr, time aflar aciministration of sedation Dr. Chaudhry exited (he Chaudhry documented intraservice time (cent Wnuaus face room) was 279 minutes. Contrast Visipaque 320 was used during the procedure, total contrast used was 200 mi. Left Heart Left Ventricia 8%, The EOP Is calculated to be 44, LV end diastolic pr essure {s sdveroly elavated. The election fraction [s calculated to ba t Wail Motion Aortic : ag efa & Syay Mitent hy a eha Se Ste aay aa oy u ios Ae aa ce i g sogments with LV Akinesia of 1 the mid infoctor wall with oversil severe hypokinesis of the remainin ejection fraction estimate d at 15%. EB Hypckinesis @ rxinesis E® ovskinesie BD Aveurysmat @Dvormar Coronary Findings Dominance: Right Left Main ly normal, The vessel originates from the left coronary The vessel was visualized by angiography, is large and is angiographical simis, Lett Anterlor Descending he ie a . [KLARA] at 9/7/17 10:42 AM Page 2 of 6 Greer, Frederick (MR # M590736) Printed by Karen Lara [Page15 of 91) Cardiology Associate POTSmodem! _ 10/12/2018 02:55:57 PM -0400 ‘Chart}[Fredevick Greer][89940] = Se Greer, Frederick (MR 4 M590736) ‘The vessal is moderate in size, The vessel is moderately calcified. + Prox LAD lesion, 30% stenosis. + Mid LAD lesion, 60% stenosis, + Dist LAD fasion, 70% stenosis. Loft Cireumttox ‘The vossatis moderate in size. + Prox Cx laston, 100% stenosis, Culprit lesion. The tesion is C = 20mm or grsater. The lasion was nat previously treated. + PCI: Lesion tength: 30 mm. The guidewire cros sed lesion, Angtoplasty alone was performed, There is no pre-Interventional antegrade distal fw (FIM(O). There is no post interventional aniagrade distal flaw (TIMI 0). The intervention was unsuccessful, No reflow due to non viable myocardium ‘Al this lasion, a perforation of the vessel occurred. Pressure IVUS was not pe “formed on the lesion. No optleal coherence tomography WwirelFFR was not performed on the lesion.wasn't (OCT) was performed, The intervention successful, + There is 2 100% residual stenosis post intervention, Right Goronary Artory coronary sinus. The ‘The vessel was visualized by angiography and is moderate in size, The ves: sel originates from the right vaasel ig maderately calcifia + Mid RCA lesion, 95% stenosis, + Dist RCA+T lesion, 60% stenosis. + Dist RCA-2 fasion, 70% stenosis. Condition Catdiac Oulput Sysieinie Arterial Eaumarad OF Condition RR BSA Memaglobin KO 106 bern 2.42 m2 3.1 gfdt. 133 321.88 02 REST Pressures O2 REST Blood Cas Diastohe ROP Means Awave Wave § Data Tine Systotic AO 6:55 AM 413 mmHg 84 mmr 96 mmHg 7:10 AM 107 mmHg 30 malig 91 mmtg 7:29 AM 100. mmHg 74 ramHg 83 mmHg 7:52 AM 62 mmiig 48 mniig 62 mmHg AN 63 mmHg 50 mmiig 55 mmHg 8:02 AM 132 mmHg, 88 mmHg 102 mrtg 8:07 AM 126 mmbig 94 mmitg 105 mmbig B10 AM 124 mmb4g 9t mmitg 102 mmHg B12 AM 145 mmtig 85 mma 96 mtg 8:20 AM 94 mmHg 88 mmHg 78 mmeg 8:23 AM 17 mmHg 99. mmHg 107 mmtig 8:24 AM 79 mmHg 87 mmHg 74 mmHg 8:27 AM 125 mmHg 116 mmitg 121 mmHg 8:42 AM a7 mmtg, 81 mmHg 64 mmHg 6:42 AM 82 mmHg 47 mmHg 65 mmHg 8:45 AM 122 mmHg 70 mmHg 8a mmHg, 8:47 AM 101 mmHg 87 mrtg 73 mmHa 6:48 AM 133 mmHg 77 mmHg 97 mmHg 8:55 AM 105 mmg 62 mmHg 77 mmHg 0:05 AM - 106 mmHg 84 mratig 78 mmHg 8:10 AM 70 mmHg 38 mentig 60 mmHg 9:12 AM 69 mmHg 44 mmHg 51 mmHg Ww 7:00 AM 124 mmHg, +6. mmHg 44 mmHg AOp “7:60 AM 419. mmHg 48 mtg 6 mmHg LVp 7:00 AM 424 mmHg 47 meng 99 mmHg Blood Oximetry 9/1/17 0639--9/1/17 1057 SpO2 Bale/Time Pulse Rasp Be 20 128/86 92% NOAM. O8: 34. 87 112/64 Ss OgiOttT 10:16:32 103 ae [KLARA] at 9/7/17 10:42 AM Page 3 Greer, Frederick (MR # M590736) Printed by Karen Lara {Page 16 of 91} ‘ (18/92) 10/12/2018 02:56:57 PM -0400 Card io logy Associate POTSmodem) Chart)[Brederick Grees(89540) _— — = —— a . Greer, Frederick (MR # MS90736) O9/O117 10:25:08 102 18 494770 -“Tmpella:insertion iri Insertion The parformance favel was PO. The Impella was nat reposivonad, Gardize er Was Insorted Io the tal ft famoral artory. “gutput wae 3 (rnin, } Pericardiscentesis Poiteardiush apical and parastamal ap: proach with flyare and with uitrasoun d, Unguccesstut attempt at Pericandioceit jesis performed byfromthe cltast Wall {6 poriodrdlum , Bodside pericardia l window performe d by Dr, Crouch, pericardiocante: sis given-dapt h Suri Génclusio 4 days old in the setting of Q waves across the Gedliision of the proximal left circumflex artery which is likely angioplasty with no O flow,:100%,ocelusion, culprit vess: Jal) status post balloon ‘dial tamipangde reqititing