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Filing # 181259858 E-Filed 09/06/2023 06:21:45 PM
IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
Plaintiff,
v.
MICHAEL G. EDWARDS and
HHS ENVIRONMENTAL SERVICES, LLC and
PORT CHARLOTTE HMA, LLC d/b/a
SHOREPOINT HEALTH PORT CHARLOTTE,
f/k/a BAYFRONT HEALTH PORT CHARLOTTE,
Defendants.
___________________________________/
ENVIRONMENTAL SERVICES, LLC.’S, NOTICE OF SERVING
SECOND UPDATED INTERROGATORIES TO PLAINTIFF, BARBARA GONZALEZ
Defendants, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES,
the Florida Rules of
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed to all
counsel of the attached Service List this 6 day of September, 2023.
KUBICKI DRAPER
9100 South Dadeland Blvd.
Suite 1800
Miami, FL 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
Pleadings:
By: /s/ Francesca Ippolito-Craven
FRANCESCA IPPOLITO-CRAVEN
Florida Bar Number: 0145361
JESSICA M. DEL SOL
jmd@kubickidraper.com
Florida Bar Number: 1031645
SERVICE LIST
STRATIGAKOS LAW, P.A.
412 East Madison Street, Suite 814
Tampa, FL 33602
Primary: Helen@stratigakoslaw.com
admin@stratigakoslaw.com
Co-counsel for Plaintiff:
Michael J. Rossi, Esq.
MICHAEL J. ROSSI, P.A.
115 South Albany Avenue
Tampa, FL 33606
michael@michaelrossilaw.com
Counsel for Port Charlotte HMA, LLC d/b/a Bayfront Health Port Charlotte
Julie A. Campbell, Esquire
Brittany A. Perez, Esquire
WICKER SMITH O'HARA McCOY & FORD, PA.
9132 Strada Pl., Suite 400
Naples, FL 34108
NAPcrtpleadings@wickersmith.com
SECOND UPDATED SET OF INTERROGATORIES
ogatories are to supply Defendant with information
learned or developed since Plaintiff’s answers to the last set of interrogatories answered by
Plaintiff on October 7, 2022.
1. List the name and address of your employer(s), if any, from the date of your previous and
last Answers to Interrogatories to the present time, including the dates of employment
and the wages earned with each employer.
ANSWER:
2. Describe any and all accidents and/or pers
signing the previous and last Answers to Interrogatories, and for each give the names and
on of the accident, the date and time of its
occurrence, all injuries sustained, names and addresses of treating and consulting
physicians, period of disability, names and addresses of hospitals of confinement.
ANSWER:
3. Set forth, with respect to every doctor from whom you have received medical care and
treatment as a result of the accident or incident alleged in this case since the date of your
last Answers to Interrogatories filed herein the name and address of
ich you sought treatment following said accident
or incident.
ANSWER:
4. List the names and business addresses of each physician who has treated or examined you
since October 7, 2022. and each medical facility where you have received any treatment
or examination for the injuries for which you seek damages in this cas
each the date of treatment or examination and the injury or condition for which you were
examined or treated.
Physician * Date(s) of treatment or * Injury or
or medical facility * examination * Condition
* *
* *
ANSWER:
5. List the names and business addresses of: medical facilities,
other health care providers by whom or at which you have
been examined or treated since October 7, 2022; any pharmacies where you have filled
prescriptions, and state as to each the dates of examination, treatment, dates prescription
were filled; and the condition or injury for which you were examined or treated.
Physician/ *Date(s) of treatment or *Injury or Condition
Medical facility *examination; Pharmacy *Date(s)prescription filled;
* *
* *
* *
ANSWER:
6. State whether or not you have been admitted to any hospital or institution for examination
or treatment, and if so, state the name and address of each such hospital or institution and
or confined therein. Also state, in each
instance, whether such hospitalization was for treatment of injuries sustained in this
alleged accident or incident.
ANSWER:
7. State and itemize all expenses
. Indicate to whom
each item has been paid, or is owed, and the nature of such expense.
ANSWER:
8. State the names and addresses of any witne
ANSWER:
9. Have you been convicted of a crime since
case? If so, how many times and state specifically as to each such conviction the
following: the name of the crime, the date me of the court in
nd state of the court of conviction.
ANSWER:
10. State whether you have traveled outside of
the U.S. and internationally) since you last an
the destination of each trip, the dates traveled the purpose for the travel and the names
and addresses of all individuals with whom you traveled.
ANSWER:
STATE OF FLORIDA )
: ss
COUNTY OF ___________ )
BEFORE ME, the undersigned authority,
who, being by me first duly swor
driver's license as identification ___
________________________________________
BARBARA GONZALEZ
SWORN TO AND SUBSCRIBED before me on ______________________________.
__________________________________________
Notary Public
State of Florida at Large
My Commission Expires:
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Filing # 181259858 E-Filed 09/06/2023 06:21:45 PM IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, Plaintiff, v. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC and PORT CHARLOTTE HMA, LLC d/b/a SHOREPOINT HEALTH PORT CHARLOTTE, f/k/a BAYFRONT HEALTH PORT CHARLOTTE, Defendants. ___________________________________/ ENVIRONMENTAL SERVICES, LLC.’S, NOTICE OF SERVING SECOND UPDATED INTERROGATORIES TO PLAINTIFF, BARBARA GONZALEZ Defendants, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, the Florida Rules of CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed to all counsel of the attached Service List this 6 day of September, 2023. KUBICKI DRAPER 9100 South Dadeland Blvd. Suite 1800 Miami, FL 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 Pleadings: By: /s/ Francesca Ippolito-Craven FRANCESCA IPPOLITO-CRAVEN Florida Bar Number: 0145361 JESSICA M. DEL SOL jmd@kubickidraper.com Florida Bar Number: 1031645 SERVICE LIST STRATIGAKOS LAW, P.A. 412 East Madison Street, Suite 814 Tampa, FL 33602 Primary: Helen@stratigakoslaw.com admin@stratigakoslaw.com Co-counsel for Plaintiff: Michael J. Rossi, Esq. MICHAEL J. ROSSI, P.A. 115 South Albany Avenue Tampa, FL 33606 michael@michaelrossilaw.com Counsel for Port Charlotte HMA, LLC d/b/a Bayfront Health Port Charlotte Julie A. Campbell, Esquire Brittany A. Perez, Esquire WICKER SMITH O'HARA McCOY & FORD, PA. 9132 Strada Pl., Suite 400 Naples, FL 34108 NAPcrtpleadings@wickersmith.com SECOND UPDATED SET OF INTERROGATORIES ogatories are to supply Defendant with information learned or developed since Plaintiff’s answers to the last set of interrogatories answered by Plaintiff on October 7, 2022. 1. List the name and address of your employer(s), if any, from the date of your previous and last Answers to Interrogatories to the present time, including the dates of employment and the wages earned with each employer. ANSWER: 2. Describe any and all accidents and/or pers signing the previous and last Answers to Interrogatories, and for each give the names and on of the accident, the date and time of its occurrence, all injuries sustained, names and addresses of treating and consulting physicians, period of disability, names and addresses of hospitals of confinement. ANSWER: 3. Set forth, with respect to every doctor from whom you have received medical care and treatment as a result of the accident or incident alleged in this case since the date of your last Answers to Interrogatories filed herein the name and address of ich you sought treatment following said accident or incident. ANSWER: 4. List the names and business addresses of each physician who has treated or examined you since October 7, 2022. and each medical facility where you have received any treatment or examination for the injuries for which you seek damages in this cas each the date of treatment or examination and the injury or condition for which you were examined or treated. Physician * Date(s) of treatment or * Injury or or medical facility * examination * Condition * * * * ANSWER: 5. List the names and business addresses of: medical facilities, other health care providers by whom or at which you have been examined or treated since October 7, 2022; any pharmacies where you have filled prescriptions, and state as to each the dates of examination, treatment, dates prescription were filled; and the condition or injury for which you were examined or treated. Physician/ *Date(s) of treatment or *Injury or Condition Medical facility *examination; Pharmacy *Date(s)prescription filled; * * * * * * ANSWER: 6. State whether or not you have been admitted to any hospital or institution for examination or treatment, and if so, state the name and address of each such hospital or institution and or confined therein. Also state, in each instance, whether such hospitalization was for treatment of injuries sustained in this alleged accident or incident. ANSWER: 7. State and itemize all expenses . Indicate to whom each item has been paid, or is owed, and the nature of such expense. ANSWER: 8. State the names and addresses of any witne ANSWER: 9. Have you been convicted of a crime since case? If so, how many times and state specifically as to each such conviction the following: the name of the crime, the date me of the court in nd state of the court of conviction. ANSWER: 10. State whether you have traveled outside of the U.S. and internationally) since you last an the destination of each trip, the dates traveled the purpose for the travel and the names and addresses of all individuals with whom you traveled. ANSWER: STATE OF FLORIDA ) : ss COUNTY OF ___________ ) BEFORE ME, the undersigned authority, who, being by me first duly swor driver's license as identification ___ ________________________________________ BARBARA GONZALEZ SWORN TO AND SUBSCRIBED before me on ______________________________. __________________________________________ Notary Public State of Florida at Large My Commission Expires: