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Filing # 105148871 E-Filed 03/19/2020 12:18:22 PM
IN THE CIRCUIT COURT OF THE
1978 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, Ill 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, PA, a Florida Profit
Corporation,
Defendants.
/
PLAINTIFFS’ MOTION REQUESTING PERMISSION TO USE AGREED TO
EXHIBITS AND DEPOSITION TESTIMONY DURING OPENING
COMES NOW, the Plaintiffs, FREDERIC CHARLES GREER, II] 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 moves this
Honorable Court for the entry of an Order on Plaintiffs requesting permission to use agreed to
exhibits and deposition testimony during trial and as grounds therefore states as follows:
1 The Plaintiffs request permission to use agreed to exhibits and deposition
testimony during opening.
2 An Exhibit Exchange will be scheduled.
Electronically Filed Martin 03/19/2020 12:18 PM
3 All exhibits will be made available to all parties for examination and all parties
will initial each other’s exhibit list and exhibits.
4. Only those exhibits properly listed an initialed may be offered into evidence.
5 All demonstrative exhibits will be brought to the Exhibit Exchange and signed off
on.
WHEREFORE, Plaintiff, LELAND MOWER, III, respectfully request this Court enter an
Order requesting the courts permission to use agreed to exhibits and deposition testimony during
opening.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via
electronic mail on this al * day of Mach , 2020 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: ple: ings; somerasilva.com
Secondary Email: lit fisomerasilva.com
Attorneys for Plaint
By:
PETER J. SON RA JR., ESQ
FBN: 0054267
PAUL M. SILVA, M.D., ESQ
FBN: 0319820
SERVICE LIST
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.con’
(Counsels for Defendant, Martin Memorial Medical Center, Inc.
d/b/a Martin Memorial 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: service uyalaw.corr
Secondary Email: kpuya@puyalaw.com
(Counsels for Defendants, Kunal Chaudhry, M.D. and Cardiology
Associates of Stuart, P.A.)
Dinah Stein, Esq.
Hicks, Porter, Ebenfeld & Stein, PA
799 Brickell Plaza, 9" Floor
Miami, FL 33131
Primary Emails: dstein@mhickslaw.com
akozub@mbhickslaw.com
Secondary Email: eclerk@mhickslaw.com
(Counsel for Defendants, Kunal Chaudhry, M.D. and Cardiology
Associates of Stuart, P.A.)
Adam J. Richardson, Esq.
Burlington & Rockenbach, P.A.
Courthouse Commons/Suite 350
444 West Railroad Avenue
West Palm Beach, FL 33401
Primary Email: ajr@FLAppellateLaw.com
Secondary Email: fa@FLAppellateLaw.cor:
(Appellate Counsel for Plaintiffs)
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Filing # 105148871 E-Filed 03/19/2020 12:18:22 PM IN THE CIRCUIT COURT OF THE 1978 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, Ill 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, PA, a Florida Profit Corporation, Defendants. / PLAINTIFFS’ MOTION REQUESTING PERMISSION TO USE AGREED TO EXHIBITS AND DEPOSITION TESTIMONY DURING OPENING COMES NOW, the Plaintiffs, FREDERIC CHARLES GREER, II] 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 moves this Honorable Court for the entry of an Order on Plaintiffs requesting permission to use agreed to exhibits and deposition testimony during trial and as grounds therefore states as follows: 1 The Plaintiffs request permission to use agreed to exhibits and deposition testimony during opening. 2 An Exhibit Exchange will be scheduled. Electronically Filed Martin 03/19/2020 12:18 PM 3 All exhibits will be made available to all parties for examination and all parties will initial each other’s exhibit list and exhibits. 4. Only those exhibits properly listed an initialed may be offered into evidence. 5 All demonstrative exhibits will be brought to the Exhibit Exchange and signed off on. WHEREFORE, Plaintiff, LELAND MOWER, III, respectfully request this Court enter an Order requesting the courts permission to use agreed to exhibits and deposition testimony during opening. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic mail on this al * day of Mach , 2020 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: ple: ings; somerasilva.com Secondary Email: lit fisomerasilva.com Attorneys for Plaint By: PETER J. SON RA JR., ESQ FBN: 0054267 PAUL M. SILVA, M.D., ESQ FBN: 0319820 SERVICE LIST 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.con’ (Counsels for Defendant, Martin Memorial Medical Center, Inc. d/b/a Martin Memorial 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: service uyalaw.corr Secondary Email: kpuya@puyalaw.com (Counsels for Defendants, Kunal Chaudhry, M.D. and Cardiology Associates of Stuart, P.A.) Dinah Stein, Esq. Hicks, Porter, Ebenfeld & Stein, PA 799 Brickell Plaza, 9" Floor Miami, FL 33131 Primary Emails: dstein@mhickslaw.com akozub@mbhickslaw.com Secondary Email: eclerk@mhickslaw.com (Counsel for Defendants, Kunal Chaudhry, M.D. and Cardiology Associates of Stuart, P.A.) Adam J. Richardson, Esq. Burlington & Rockenbach, P.A. Courthouse Commons/Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Primary Email: ajr@FLAppellateLaw.com Secondary Email: fa@FLAppellateLaw.cor: (Appellate Counsel for Plaintiffs)