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Filing # 105606699 E-Filed 03/30/2020 12:59:08 PM
IN THE CIRCUIT COURT OF THE 19%
JUDICIAL CIRCUIT OF FLORIDA,
IN AND FOR ST. LUCIE COUNTY, FLORIDA
FREDERIC CHARLES GREER, III, and CASE NO. 2019-000015-CA
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.
/
MARTIN MEMORIAL MEDICAL CENTER, INC.’S
NOTICE OF SERVING UPDATED INTERROGATORIES TO PLAINTIFFS
Defendant MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN
MEDICAL CENTER, by and through undersigned counsel hereby give notice of Propounding
Updated Interrogatories to Plaintiffs FREDERIC CHARLES GREER, III and MELISSA
ANNE GREER, to be answered pursuant to Rule 1.340 of the Florida Rules of Civil Procedure.
Electronically Filed Martin 03/30/2020 12:59 PM
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this 30" day of March, 2020 a copy of the foregoing
was filed and served via the Florida Courts’ E-Filing Portal to all parties listed on the attached
service list.
STEARNS WEAVER MILLER
WEISSLER ALHADEFF & SITTERSON, P.A.
Attorneys for Defendants
200 East Las Olas Blvd., Suite 2100
Fort Lauderdale, FL 33301
Telephone: (954) 462-9500
Facsimile: (954) 462-9567
By /s/ Thomas G. Aubin
THOMAS G. AUBIN, ESQUIRE
FBN: 008060
taubin@stcarnsweaver,com
MATTHEW S. PODOLNICK, ESQUIRE
FBN: 112126
mpodolnick@stearnsweaver.com
SERVICE LIST
Peter J. Somera Jr., Esq. Keith J. Puya, Esq.
Paul M. Silva, M.D., Esq. Hector R. Buigas, Esq.
Somera & Silva, LLP Law Offices of Keith J. Puya, P.A.
2255 Glades Road, Suite 232W 4880 Donald Ross Road, Suite 225
Boca Raton, FL 33431 Palm Beach Gardens, FL 33418
Phone: (561) 981-8881 Phone: (561) 408-3772
Fax: (561) 981-8887 Fax: (561) 408-3759
pleadings@somerasilva.com eservice@puyalaw.com
litigation@somerasilva.con Attorneys for Defendants Kunal Chaudhry,
Attorneys for Plaintiffs M.D. and Cardiology Associates of Stuart,
PA.
Dinah Stein, Esq. Adam Richardson, Esq.
Hicks, Poerter, Ebenfeld & Stein Burlington & Rockenbach, P.A.
799 Brickell Plaza, 9 Floor 444 West Railroad Avenue
Miami, FL 33131 West Palm Beach, FL 33401
Phone: (305) 375-8171 Tel: 561-721-0400
dste’ ickslaw.com ajr@FLAppellateLaw.com
Attorneys for Defendants Kunal Chaudhry, fa@FLAppellateLaw.com
M.D. and Cardiology Associates of Stuart, Appellate attorneys for Plaintiffs
P.A.
INTRODUCTION TO UPDATED INTERROGATORIES
Under the Fla. R. Civ. P. Rule 1.340, Interrogatories can involve an opinion or contention
that relates to fact or calls for conclusion or asks for information not within the personal
knowledge of the party.
A party shall respond to such interrogatory by giving the information he has and the
source upon which the information is based. If sufficient space is not provided
hereinafter for your complete and full answer to each question, you are to attach to your
answers additional papers containing your complete and full answer to each said question
for which additional space is needed.
DEFINITIONS
“Person” shall mean and include a natural person, partnership, firm or corporation or any
other kind of business or legal entity, its agent or employees.
In each instance wherein you are asked to “identify” a person or business, or the answer
to the question refers to a person or business, state with respect to each such person:
(1) His name;
(2) His last known residence, business address (both physical and mailing address)
and telephone;
(3) His company affiliation at the date of the transaction referred to;
(4) His title and duties in the company with which he was affiliated.
(The mail gender includes the female, and the singular pronoun includes the
plural)
The words “Document” and “Documents” means all written, recorded, or graphic
matters, including the originals and all non-identical copies, however produced and
reproduced, whether or not privilege, pertaining in any way to the subject matter of this
action. This definition includes, but is not limited to, correspondence, memoranda, notes,
diaries, statistics, letters, telegrams, minutes, contracts, reports, studies, checks,
statements, receipts, returns, summaries, pamphlets, books, prospective, inter-office and
intro-office communications, bulletins, printed matter, computer print-outs, teletypes,
telefax, invoices, worksheets, schedules, agreements, drawings, sketches, invoices, orders
or acknowledgements, diaries, appointment books, forecasts, appraisals, video-tapes,
audio-tapes, transcripts or recordings, photographs, pictures or films, computer programs
or data or other graphic, symbolic, recorded or written materials of any nature
whatsoever, (and all drafts, alterations, modifications, changes and amendments of any of
the foregoing) microfilm, microfiche, motion pictures, and electronic, mechanical or
electric records or representations of any kind including, without limitations, cassettes
and disc recordings.
In each instance wherein you are asked to “identify” a person or business, or the answer
to the question refers to a person or business, state with respect to each such person:
() his name;
(2) his last known residence, business address, and telephone;
(3) his company affiliation at the date of the transaction referred to;
(4) his title and duties in the company with which he was affiliated.
(The male gender includes the female, and the singular pronoun includes the plural)
In each instance wherein you are asked to “identify” or describe a document, your
description should include, but not be limited to:
Q) the name, address, telephone number, occupation, job title and employer of the
present custodian of the documents;
(2) the fact or facts which would tend to be established by the introduction into
evidence of each such document;
(3) the date of the making of the document and the name, address, telephone number,
occupation, job title and employer of each person whose testimony could be used
to authenticate such document and lay the foundation for its introduction into
evidence.
“You” shall refer to the party to whom these Interrogatories are directed, as well as
counsel and any consultants, experts, investigators, agents, employees, servants, or other
persons acting on behalf of said party.
“Knowledge” includes first-hand information and information derived from any other
source including hearsay knowledge.
“Business” shall mean a natural person, sole proprietorship, general partnership, limited
partnership, joint venture, unincorporated firm or association, corporation or any other
kind of business or legal entity, its agents or employees.
When asked to state the “factual basis,” please state: all facts known by you which form
the basis for a specified allegation and which relate directly to or indirectly to the
specified allegation; the applicable date(s) of the activity involved; how you acquired or
obtained such factual information; from whom you acquired or obtained such factual
information; and when you acquired such factual information.
UPDATED INTERROGATORIES
TO PLAINTIFFS FREDERIC CHARLES GREER, III and MELISSA ANN GREER
In accordance with Rule 1.340(e) of the Fla. R. Civ. P., sufficient space has been provided after each
interrogatory for the answer to be inserted. However, if, more space is needed, you should append the
answer to the interrogatory, making reference to such attachment in the space provided for the answer. The
Rule does not provide for placing all the answers on a single, separate page.
1 Identify each person who has answered or contributed any information used in
answering these interrogatories. If more than one person provided the information, state
which person(s) provided information used in answering each interrogatory
ANSWER:
List the names and business addresses of any and all physicians by whom FREDERIC
CHARLES GREER, III has been examined or treated since serving your Answers to
Interrogatories on April 19, 2019, including but not limited to neurologists,
nephrologists, internal
cardiologists, medicine physicians, endocrinologists,
urologists, gastroenterologists, cardiovascular surgeons, ophthalmologists, dentists,
hematologists, physical medicine and rehabilitation physicians, doctors of
osteopathy, emergency room physicians, advanced registered nurse practitioners,
and/or physician assistants, and state as to each the dates of examination or treatment
and the condition or injury for which FREDERIC CHARLES GREER, III was examined
or treated.
ANSWER:
3 List the names of any and all hospitals, clinics, and/or emergency departments at
which FREDERIC CHARLES GREER, III has been examined or treated since serving
your Answers to Interrogatories on April 19, 2019, and state as to each the dates of
examination, treatment, and/or presentation, and the condition or injury for which
FREDERIC CHARLES GREER, III was examined or treated.
ANSWER:
4. List the names and business addresses of any and all psychiatrists, psychologists,
neuropsychologists, counselors and/or mental health therapists by whom FREDERIC
CHARLES GREER, III has been examined or treated since serving your Answers to
Interrogatories on April 19, 2019, and state as to each the dates of examination or
treatment and the condition or injury for which FREDERIC CHARLES GREER, III was
examined or treated.
ANSWER:
5 List any and all falls FREDERIC CHARLES GREER, III has suffered since
serving your Answers to Interrogatories on April 19, 2019, as well as:
a The circumstances of the fall;
b Whether the fall required medical treatment; and
c. The location and date of medical treatment related to the fall;
d. The injuries alleged suffered from as related to the fall.
ANSWER:
6. List any vacations or trips FREDERIC CHARLES GREER, III has taken serving
your Answers to Interrogatories on April 19, 2019.
ANSWER:
7. Please list any and all scheduled appointments you may have with any of the providers
listed in your answers to Numbers 2 and 4, above, or with any other health care or mental
health provider not listed above, as well as the date(s) of the appointment(s).
ANSWER:
Please list any scheduled independent medical examinations (IMEs) you may have with
any health care provider or mental health specialist, as well as the date(s) of the IME(s),
whether retained by your lawyers, appointed by any other agency or healthcare provider,
or workers’ compensation plan or seen independently.
ANSWER:
Please list any and all consultations you may have had, in phone, in person, or through
any form of electronic communication (email, text messaging, Skype, Facetime, Zoom,
etc.), with any of the providers listed in your answers to Numbers 2 and 4, above, or with
any other health care or mental health provider not listed above, as well as the date(s) of
the consultation(s).
ANSWER:
I HEREBY ACKNOWLEDGE THAT THE ABOVE AND FOREGOING ANSWERS
TO INTERROGATORIES ARE TRUE AND CORRECT TO THE BEST OF MY
KNOWLEDGE.
FREDERIC CHARLES GREER, III
STATE OF FLORIDA
COUNTY OF
The foregoing Verified Answers to Updated Interrogatories were acknowledged before
me this day of , 2020 by , who is personally
known to me, or who has produced as
identification, and who did take an oath.
NOTARY PUBLIC
(Print Name of notary public)
My commission expires:
#8291716 v1
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Filing # 105606699 E-Filed 03/30/2020 12:59:08 PM IN THE CIRCUIT COURT OF THE 19% JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR ST. LUCIE COUNTY, FLORIDA FREDERIC CHARLES GREER, III, and CASE NO. 2019-000015-CA 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. / MARTIN MEMORIAL MEDICAL CENTER, INC.’S NOTICE OF SERVING UPDATED INTERROGATORIES TO PLAINTIFFS Defendant MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER, by and through undersigned counsel hereby give notice of Propounding Updated Interrogatories to Plaintiffs FREDERIC CHARLES GREER, III and MELISSA ANNE GREER, to be answered pursuant to Rule 1.340 of the Florida Rules of Civil Procedure. Electronically Filed Martin 03/30/2020 12:59 PM CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this 30" day of March, 2020 a copy of the foregoing was filed and served via the Florida Courts’ E-Filing Portal to all parties listed on the attached service list. STEARNS WEAVER MILLER WEISSLER ALHADEFF & SITTERSON, P.A. Attorneys for Defendants 200 East Las Olas Blvd., Suite 2100 Fort Lauderdale, FL 33301 Telephone: (954) 462-9500 Facsimile: (954) 462-9567 By /s/ Thomas G. Aubin THOMAS G. AUBIN, ESQUIRE FBN: 008060 taubin@stcarnsweaver,com MATTHEW S. PODOLNICK, ESQUIRE FBN: 112126 mpodolnick@stearnsweaver.com SERVICE LIST Peter J. Somera Jr., Esq. Keith J. Puya, Esq. Paul M. Silva, M.D., Esq. Hector R. Buigas, Esq. Somera & Silva, LLP Law Offices of Keith J. Puya, P.A. 2255 Glades Road, Suite 232W 4880 Donald Ross Road, Suite 225 Boca Raton, FL 33431 Palm Beach Gardens, FL 33418 Phone: (561) 981-8881 Phone: (561) 408-3772 Fax: (561) 981-8887 Fax: (561) 408-3759 pleadings@somerasilva.com eservice@puyalaw.com litigation@somerasilva.con Attorneys for Defendants Kunal Chaudhry, Attorneys for Plaintiffs M.D. and Cardiology Associates of Stuart, PA. Dinah Stein, Esq. Adam Richardson, Esq. Hicks, Poerter, Ebenfeld & Stein Burlington & Rockenbach, P.A. 799 Brickell Plaza, 9 Floor 444 West Railroad Avenue Miami, FL 33131 West Palm Beach, FL 33401 Phone: (305) 375-8171 Tel: 561-721-0400 dste’ ickslaw.com ajr@FLAppellateLaw.com Attorneys for Defendants Kunal Chaudhry, fa@FLAppellateLaw.com M.D. and Cardiology Associates of Stuart, Appellate attorneys for Plaintiffs P.A. INTRODUCTION TO UPDATED INTERROGATORIES Under the Fla. R. Civ. P. Rule 1.340, Interrogatories can involve an opinion or contention that relates to fact or calls for conclusion or asks for information not within the personal knowledge of the party. A party shall respond to such interrogatory by giving the information he has and the source upon which the information is based. If sufficient space is not provided hereinafter for your complete and full answer to each question, you are to attach to your answers additional papers containing your complete and full answer to each said question for which additional space is needed. DEFINITIONS “Person” shall mean and include a natural person, partnership, firm or corporation or any other kind of business or legal entity, its agent or employees. In each instance wherein you are asked to “identify” a person or business, or the answer to the question refers to a person or business, state with respect to each such person: (1) His name; (2) His last known residence, business address (both physical and mailing address) and telephone; (3) His company affiliation at the date of the transaction referred to; (4) His title and duties in the company with which he was affiliated. (The mail gender includes the female, and the singular pronoun includes the plural) The words “Document” and “Documents” means all written, recorded, or graphic matters, including the originals and all non-identical copies, however produced and reproduced, whether or not privilege, pertaining in any way to the subject matter of this action. This definition includes, but is not limited to, correspondence, memoranda, notes, diaries, statistics, letters, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, prospective, inter-office and intro-office communications, bulletins, printed matter, computer print-outs, teletypes, telefax, invoices, worksheets, schedules, agreements, drawings, sketches, invoices, orders or acknowledgements, diaries, appointment books, forecasts, appraisals, video-tapes, audio-tapes, transcripts or recordings, photographs, pictures or films, computer programs or data or other graphic, symbolic, recorded or written materials of any nature whatsoever, (and all drafts, alterations, modifications, changes and amendments of any of the foregoing) microfilm, microfiche, motion pictures, and electronic, mechanical or electric records or representations of any kind including, without limitations, cassettes and disc recordings. In each instance wherein you are asked to “identify” a person or business, or the answer to the question refers to a person or business, state with respect to each such person: () his name; (2) his last known residence, business address, and telephone; (3) his company affiliation at the date of the transaction referred to; (4) his title and duties in the company with which he was affiliated. (The male gender includes the female, and the singular pronoun includes the plural) In each instance wherein you are asked to “identify” or describe a document, your description should include, but not be limited to: Q) the name, address, telephone number, occupation, job title and employer of the present custodian of the documents; (2) the fact or facts which would tend to be established by the introduction into evidence of each such document; (3) the date of the making of the document and the name, address, telephone number, occupation, job title and employer of each person whose testimony could be used to authenticate such document and lay the foundation for its introduction into evidence. “You” shall refer to the party to whom these Interrogatories are directed, as well as counsel and any consultants, experts, investigators, agents, employees, servants, or other persons acting on behalf of said party. “Knowledge” includes first-hand information and information derived from any other source including hearsay knowledge. “Business” shall mean a natural person, sole proprietorship, general partnership, limited partnership, joint venture, unincorporated firm or association, corporation or any other kind of business or legal entity, its agents or employees. When asked to state the “factual basis,” please state: all facts known by you which form the basis for a specified allegation and which relate directly to or indirectly to the specified allegation; the applicable date(s) of the activity involved; how you acquired or obtained such factual information; from whom you acquired or obtained such factual information; and when you acquired such factual information. UPDATED INTERROGATORIES TO PLAINTIFFS FREDERIC CHARLES GREER, III and MELISSA ANN GREER In accordance with Rule 1.340(e) of the Fla. R. Civ. P., sufficient space has been provided after each interrogatory for the answer to be inserted. However, if, more space is needed, you should append the answer to the interrogatory, making reference to such attachment in the space provided for the answer. The Rule does not provide for placing all the answers on a single, separate page. 1 Identify each person who has answered or contributed any information used in answering these interrogatories. If more than one person provided the information, state which person(s) provided information used in answering each interrogatory ANSWER: List the names and business addresses of any and all physicians by whom FREDERIC CHARLES GREER, III has been examined or treated since serving your Answers to Interrogatories on April 19, 2019, including but not limited to neurologists, nephrologists, internal cardiologists, medicine physicians, endocrinologists, urologists, gastroenterologists, cardiovascular surgeons, ophthalmologists, dentists, hematologists, physical medicine and rehabilitation physicians, doctors of osteopathy, emergency room physicians, advanced registered nurse practitioners, and/or physician assistants, and state as to each the dates of examination or treatment and the condition or injury for which FREDERIC CHARLES GREER, III was examined or treated. ANSWER: 3 List the names of any and all hospitals, clinics, and/or emergency departments at which FREDERIC CHARLES GREER, III has been examined or treated since serving your Answers to Interrogatories on April 19, 2019, and state as to each the dates of examination, treatment, and/or presentation, and the condition or injury for which FREDERIC CHARLES GREER, III was examined or treated. ANSWER: 4. List the names and business addresses of any and all psychiatrists, psychologists, neuropsychologists, counselors and/or mental health therapists by whom FREDERIC CHARLES GREER, III has been examined or treated since serving your Answers to Interrogatories on April 19, 2019, and state as to each the dates of examination or treatment and the condition or injury for which FREDERIC CHARLES GREER, III was examined or treated. ANSWER: 5 List any and all falls FREDERIC CHARLES GREER, III has suffered since serving your Answers to Interrogatories on April 19, 2019, as well as: a The circumstances of the fall; b Whether the fall required medical treatment; and c. The location and date of medical treatment related to the fall; d. The injuries alleged suffered from as related to the fall. ANSWER: 6. List any vacations or trips FREDERIC CHARLES GREER, III has taken serving your Answers to Interrogatories on April 19, 2019. ANSWER: 7. Please list any and all scheduled appointments you may have with any of the providers listed in your answers to Numbers 2 and 4, above, or with any other health care or mental health provider not listed above, as well as the date(s) of the appointment(s). ANSWER: Please list any scheduled independent medical examinations (IMEs) you may have with any health care provider or mental health specialist, as well as the date(s) of the IME(s), whether retained by your lawyers, appointed by any other agency or healthcare provider, or workers’ compensation plan or seen independently. ANSWER: Please list any and all consultations you may have had, in phone, in person, or through any form of electronic communication (email, text messaging, Skype, Facetime, Zoom, etc.), with any of the providers listed in your answers to Numbers 2 and 4, above, or with any other health care or mental health provider not listed above, as well as the date(s) of the consultation(s). ANSWER: I HEREBY ACKNOWLEDGE THAT THE ABOVE AND FOREGOING ANSWERS TO INTERROGATORIES ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE. FREDERIC CHARLES GREER, III STATE OF FLORIDA COUNTY OF The foregoing Verified Answers to Updated Interrogatories were acknowledged before me this day of , 2020 by , who is personally known to me, or who has produced as identification, and who did take an oath. NOTARY PUBLIC (Print Name of notary public) My commission expires: #8291716 v1