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Filing # 126048208 E-Filed 05/03/2021 02:45:15 PM
IN THE CIRCUIT COURT OF THE
19" JUDICIAL CIRCUIT IN AND
FOR MARTIN COUNTY, FLORIDA
CASE NO: 2019-CA-000015
FREDERIC CHARLES GREER, III, and
MELISSA ANNE GREER, as Husband and
Wife, and FREDERIC CHARLES GREER, III
and MELISSA ANNE GREER, individually,
Plaintiffs,
vs.
MARTIN MEMORIAL MEDICAL CENTER,
INC. d/b/a MARTIN MEDICAL CENTER, a
Florida Corporation; KUNAL CHAUDHRY, M.D.;
and CARDIOLOGY ASSOCIATES OF STUART,
P.A., a Florida profit corporation,
Defendants.
/
2NP RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM
(Deposition to be Taken Remotely Via Zoom)
PLEASE TAKE NOTICE that the undersigned will take the deposition by oral examination
for use as evidence in said cause, of the following witness who is requested to have with her at that
time the documents listed on Exhibit “A”, attached:
Witness Date/Time Location
Gustavo R. Ruiz, May 24, 2021, at Remotely via Zoom link to be provided by
M.D. 1:00 p.m. Veritext Legal Solutions.
Videographer service also to be provided by
Veritext Legal Solutions
One E. Broward Blvd., Suite 1101
Fort Lauderdale, FL 33301
954-524-0253
PLEASE TAKE FURTHER NOTICE that:
1 The deposition will be conducted remotely, using audio-visual conference
technology;
Electronically Filed Martin 05/03/2021 02:45 PM
The court reporter will report the deposition from a location separate from the
witness;
Counsel for the parties and their clients will be participating from various,
separate locations, as designated in advance;
The witness and any party appearing by audio-visual conference will be
required to utilize a computer with audio-visual capability, or appear at location
with appropriate equipment (the parties will coordinate as to technical
requirements and other specifics in advance);
The witness will be required to provide government-issued identification
satisfactory to the court reporter, and this identification must be legible on
camera;
Each participating attorney and any other participants will be visible to all other
participants (unless the attorney appears telephonically), and their statements
will be audible to all participants;
No other participants will be permitted, unless by agreement and disclosed in
advance;
All exhibits will be provided simultaneously and electronically to the witness
and all participants;
9 The court reporter will record the testimony;
10. The deposition may be recorded electronically or may be recorded by a certified
videographer; and
11. Counsel for all parties will be required to stipulate on the record:
a. Their consent to this manner of taking deposition; and
b. Their waiver of any objection to this manner of taking deposition.
The deposition is being taken for purposes of discovery, in aid of execution, or for such
purposes as permitted under the rules of the Court.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this 3 day of May, 2021, a copy of the foregoing was
served via the Florida E-Filing Portal to the parties on the attached service list.
STEARNS WEAVER MILLER
WEISSLER ALHADEFF & SITTERSON, P.A.
Attorneys for Martin Memorial Medical Center, Inc.
200 East Las Olas Blvd., Suite 2100
Fort Lauderdale, FL 33301
Phone: (954) 462-9500
Fax: (954) 462-9567
Det.
THOMAS G. AUBIN, ESQUIRE
FBN: 008060
taubin @stearnsweaver.com
MATTHEW S. PODOLNICK, ESQUIRE
FBN: 112126
mpodolnick@stearnsweaver.com
SERVICE LIST
Peter J. Somera Jr., Esq. Geoffrey N. Fieger, Esq.
Paul M. Silva, M.D., Esq. Fieger Law
Somera & Silva, LLP 19390 West Ten Mile Road
2255 Glades Road, Suite 232W Southfield, MI 48075
Boca Raton, FL 33431 Phone: (248) 355-5555
Phone: (561) 981-8881 Fax: (248) 355-5148
Fax: (561) 981-8887 G.Fieger@Fiegerlaw.com
pleadings@somerasilva.com S.Teal Fiegerlaw.com
litigation@somerasilva.com Co-Attorneys for Plaintiffs
Attorneys for Plaintiffs
Adam Richardson, Esq. Keith J. Puya, Esq.
Bard D. Rockenbach, Esq. Hector R. Buigas, Esq.
Burlington & Rockenbach, P.A. Law Offices of Keith J. Puya, P.A.
444 West Railroad Avenue 4880 Donald Ross Road, Suite 225
West Palm Beach, FL 33401 Palm Beach Gardens, FL 33418
Tel: 561-721-0400 Phone: (561) 408-3772
ajr@FLAppellateLaw.com Fax: (561) 408-3759
bdr@FLAppellateLaw.com eservice@puyalaw.com
fa@FLAppellateLaw.com Attorneys for Defendants Kunal Chaudhry,
Appellate attorneys for Plaintiffs M.D. and Cardiology Associates of Stuart,
PA,
Dinah Stein, Esq.
Hicks, Poerter, Ebenfeld & Stein
799 Brickell Plaza, 9" Floor
Miami, FL 33131
Phone: (305) 375-8171
dstein@mhickslaw.com
Attorneys for Defendants Kunal Chaudhry,
M.D. and Cardiology Associates of Stuart,
PA.
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Filing # 126048208 E-Filed 05/03/2021 02:45:15 PM IN THE CIRCUIT COURT OF THE 19" JUDICIAL CIRCUIT IN AND FOR MARTIN COUNTY, FLORIDA CASE NO: 2019-CA-000015 FREDERIC CHARLES GREER, III, and MELISSA ANNE GREER, as Husband and Wife, and FREDERIC CHARLES GREER, III and MELISSA ANNE GREER, individually, Plaintiffs, vs. MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER, a Florida Corporation; KUNAL CHAUDHRY, M.D.; and CARDIOLOGY ASSOCIATES OF STUART, P.A., a Florida profit corporation, Defendants. / 2NP RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM (Deposition to be Taken Remotely Via Zoom) PLEASE TAKE NOTICE that the undersigned will take the deposition by oral examination for use as evidence in said cause, of the following witness who is requested to have with her at that time the documents listed on Exhibit “A”, attached: Witness Date/Time Location Gustavo R. Ruiz, May 24, 2021, at Remotely via Zoom link to be provided by M.D. 1:00 p.m. Veritext Legal Solutions. Videographer service also to be provided by Veritext Legal Solutions One E. Broward Blvd., Suite 1101 Fort Lauderdale, FL 33301 954-524-0253 PLEASE TAKE FURTHER NOTICE that: 1 The deposition will be conducted remotely, using audio-visual conference technology; Electronically Filed Martin 05/03/2021 02:45 PM The court reporter will report the deposition from a location separate from the witness; Counsel for the parties and their clients will be participating from various, separate locations, as designated in advance; The witness and any party appearing by audio-visual conference will be required to utilize a computer with audio-visual capability, or appear at location with appropriate equipment (the parties will coordinate as to technical requirements and other specifics in advance); The witness will be required to provide government-issued identification satisfactory to the court reporter, and this identification must be legible on camera; Each participating attorney and any other participants will be visible to all other participants (unless the attorney appears telephonically), and their statements will be audible to all participants; No other participants will be permitted, unless by agreement and disclosed in advance; All exhibits will be provided simultaneously and electronically to the witness and all participants; 9 The court reporter will record the testimony; 10. The deposition may be recorded electronically or may be recorded by a certified videographer; and 11. Counsel for all parties will be required to stipulate on the record: a. Their consent to this manner of taking deposition; and b. Their waiver of any objection to this manner of taking deposition. The deposition is being taken for purposes of discovery, in aid of execution, or for such purposes as permitted under the rules of the Court. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this 3 day of May, 2021, a copy of the foregoing was served via the Florida E-Filing Portal to the parties on the attached service list. STEARNS WEAVER MILLER WEISSLER ALHADEFF & SITTERSON, P.A. Attorneys for Martin Memorial Medical Center, Inc. 200 East Las Olas Blvd., Suite 2100 Fort Lauderdale, FL 33301 Phone: (954) 462-9500 Fax: (954) 462-9567 Det. THOMAS G. AUBIN, ESQUIRE FBN: 008060 taubin @stearnsweaver.com MATTHEW S. PODOLNICK, ESQUIRE FBN: 112126 mpodolnick@stearnsweaver.com SERVICE LIST Peter J. Somera Jr., Esq. Geoffrey N. Fieger, Esq. Paul M. Silva, M.D., Esq. Fieger Law Somera & Silva, LLP 19390 West Ten Mile Road 2255 Glades Road, Suite 232W Southfield, MI 48075 Boca Raton, FL 33431 Phone: (248) 355-5555 Phone: (561) 981-8881 Fax: (248) 355-5148 Fax: (561) 981-8887 G.Fieger@Fiegerlaw.com pleadings@somerasilva.com S.Teal Fiegerlaw.com litigation@somerasilva.com Co-Attorneys for Plaintiffs Attorneys for Plaintiffs Adam Richardson, Esq. Keith J. Puya, Esq. Bard D. Rockenbach, Esq. Hector R. Buigas, Esq. Burlington & Rockenbach, P.A. Law Offices of Keith J. Puya, P.A. 444 West Railroad Avenue 4880 Donald Ross Road, Suite 225 West Palm Beach, FL 33401 Palm Beach Gardens, FL 33418 Tel: 561-721-0400 Phone: (561) 408-3772 ajr@FLAppellateLaw.com Fax: (561) 408-3759 bdr@FLAppellateLaw.com eservice@puyalaw.com fa@FLAppellateLaw.com Attorneys for Defendants Kunal Chaudhry, Appellate attorneys for Plaintiffs M.D. and Cardiology Associates of Stuart, PA, Dinah Stein, Esq. Hicks, Poerter, Ebenfeld & Stein 799 Brickell Plaza, 9" Floor Miami, FL 33131 Phone: (305) 375-8171 dstein@mhickslaw.com Attorneys for Defendants Kunal Chaudhry, M.D. and Cardiology Associates of Stuart, PA.