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Filing # 103680508 E-Filed 02/21/2020 09:59:51 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.
i
RE-NOTICE OF TAKING DEPOSITION DUCES TECUM
(date change)
PLEASE TAKE NOTICE that the undersigned attorneys will take the deposition, by oral
examination, of the person or persons named below, at the time, date, and at the hour and place
indicated:
NAME: Cynthia Silva — the person with the most knowledge at Martin Medical
Center of the policies and procedures in Cardiac Cath Lab and
Interventional Cardiology Service.
See Duces Tecum attached as Exhibit “A”
DATE: February 24, 2020
TIME: 10:00 am.
PLACE: Cleveland Clinic Martin North Hospital
200 SE Hospital Avenue
Stuart, FL 34994
Electronically Filed Martin 02/21/2020 09:59 AM
Upon oral examination before Esquire Deposition or any other Notary Public or officer authorized
by law to take depositions in the State of Florida. The oral examination will continue from day to
day until completed. The deposition is being taken for the purpose of discovery, for use at trial or
for such other purposes as are permitted under the Rules of Court, including the applicable Rules
of Civil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic
mail on this2 May of _F€b{UGiy 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: pleadings@somerasilva.com
Secondary Email: litigation@somerasilva.com
Attorneys for Plaintiffs
By: (L-
FBN: i
PETER/J. SOMERA JR., ESQ.
54267
PAUL M. SILVA, M.D., ESQ.
FBN: 0319820
SERVICE LIST
Michael K. Mittelmark, Esq.
K. Calvin Asrani, Esq.
Michaud, Mittelmark & Asrani, PLLC
621 NW 53" Street, Suite 395
Boca Raton, FL 33487
Primary Email: pleadings@michaudlaw.com
Secondary Email: erhodes@michaudlaw.com
(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: eservice@puyalaw.com
Secondary Email: kpuya@puyalaw.com
(Counsels for Defendants, Kunal Chaudhry, M.D. and Cardiology
Associates of Stuart, P.A.)
*DUCES TECUM: TO HAVE AND BRING WITH YOU AT THE TIME OF THE
DEPOSITION THE FOLLOWING:
SCHEDULE "A"
DUCES TECUM
1 Any and all policy and procedures for the Cath Lab and Interventional Cardiology
Service at Martin Medical Center in effect on September 1, 2017.
*"Documents" shall include, but not be limited to all non-identical copies of writings, drawings,
graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from
which information can be obtained, translated, if necessary, by the party to whom the request is
directed through detection devices into reasonably usable form. "Documents" also include all
electronic data as well as application metadata and system metadata. All inventories and rosters of
your information technology (IT) systems—e.g., hardware, software and data, including but not
limited to network drawings, lists of computing devices (servers, PCs, laptops, PDAs, cell phones,
with data storage and/or transmission features), programs, data maps and security tools and
protocols.
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Filing # 103680508 E-Filed 02/21/2020 09:59:51 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. i RE-NOTICE OF TAKING DEPOSITION DUCES TECUM (date change) PLEASE TAKE NOTICE that the undersigned attorneys will take the deposition, by oral examination, of the person or persons named below, at the time, date, and at the hour and place indicated: NAME: Cynthia Silva — the person with the most knowledge at Martin Medical Center of the policies and procedures in Cardiac Cath Lab and Interventional Cardiology Service. See Duces Tecum attached as Exhibit “A” DATE: February 24, 2020 TIME: 10:00 am. PLACE: Cleveland Clinic Martin North Hospital 200 SE Hospital Avenue Stuart, FL 34994 Electronically Filed Martin 02/21/2020 09:59 AM Upon oral examination before Esquire Deposition or any other Notary Public or officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. The deposition is being taken for the purpose of discovery, for use at trial or for such other purposes as are permitted under the Rules of Court, including the applicable Rules of Civil Procedure. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic mail on this2 May of _F€b{UGiy 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: pleadings@somerasilva.com Secondary Email: litigation@somerasilva.com Attorneys for Plaintiffs By: (L- FBN: i PETER/J. SOMERA JR., ESQ. 54267 PAUL M. SILVA, M.D., ESQ. FBN: 0319820 SERVICE LIST Michael K. Mittelmark, Esq. K. Calvin Asrani, Esq. Michaud, Mittelmark & Asrani, PLLC 621 NW 53" Street, Suite 395 Boca Raton, FL 33487 Primary Email: pleadings@michaudlaw.com Secondary Email: erhodes@michaudlaw.com (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: eservice@puyalaw.com Secondary Email: kpuya@puyalaw.com (Counsels for Defendants, Kunal Chaudhry, M.D. and Cardiology Associates of Stuart, P.A.) *DUCES TECUM: TO HAVE AND BRING WITH YOU AT THE TIME OF THE DEPOSITION THE FOLLOWING: SCHEDULE "A" DUCES TECUM 1 Any and all policy and procedures for the Cath Lab and Interventional Cardiology Service at Martin Medical Center in effect on September 1, 2017. *"Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices into reasonably usable form. "Documents" also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) systems—e.g., hardware, software and data, including but not limited to network drawings, lists of computing devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps and security tools and protocols.