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Filing# 180249366 E-Filed 08/22/2023 03:08:53 PM
INTHE CIRCUIT COURT OF THE 17
,TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-016578
JOY FURER,
Plaintiff,
V
GG RE HOLLYWOOD BEACH 613 LLC,
and RELAXPRO, LLC,
Defendants.
i
DEFENDANT, GG RE HOLLYWOOD BEACH 613 LLC, THIRTEENTH
REQUEST FOR PRODUCTION TO PLAINTIFF
Defendant, GG RE HOLLYWOOD BEACH 613 LLC, by and through its undersigned
counsel, and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby request that
JOY
Plaintiff, FURER, produce the followingwithin thirty(30)days of service hereof:
1. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Lenox Hill Hospital (Followed
to Plaintiff counsel *** Please make sure the box for in section 9(b) is
email).
initialed and signed and dated on the bottom of the form.
2. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for East Side Endoscopy
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
3. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Dr. Arthur Lubitz (Followed
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/22/2023 03:08:53 PM.****
to Plaintiff counsel *** Please make sure the box for in section 9(b) is
email).
initialed and signed and dated on the bottom of the form.
4. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Joan V. Klein (Followed to
Plaintiff counsel *** Please make sure the box for in section 9(b) is initialed
email).
and signed and dated on the bottom of the form.
5. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Outreach Outpatient Services
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
6. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for SLR Diagnostic Radiology
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
7. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Molina Healthcare of New
*** Please make sure the box for
York, Inc. (Followed to Plaintiff counsel email).
in section 9(b) is initialed and signed and dated on the bottom of the form.
8. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Lenco Diagnostic
Laboratories (Followed to Plaintiffcounsel email).*** Please make sure the box for
in section 9(b) is initialed and signed and dated on the bottom of the form.
9. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Royal Care Pharmacy
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
10. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Boro Park OB/GYN (Followed
to Plaintiff counsel *** Please make sure the box for in section 9(b) is
email).
initialed and signed and dated on the bottom of the form.
11. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for FJ Orthopaedics and Pain
*** Please
Management PLLC (Followed to Plaintiffcounsel email). make sure the
box for in section 9(b) is initialed and signed and dated on the bottom of the form.
12. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Maiden Lane Medical, Harry
Gruenspan, MD, PHD (Followed to Plaintiff counsel email).
*** Please make sure
the box for in section 9(b) is initialed and signed and dated on the bottom of the
form.
13. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Manhattan Psychology
PC *** Please make sure the box for
Group, (Followed to Plaintiff counsel email).
in section 9(b) is initialed and signed and dated on the bottom of the form.
14. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for ParCare Community Health
Network (Followed to Plaintiff counsel *** Please make sure the box for in
email).
section 9(b) is initialed and signed and dated on the bottom of the form.
15. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Stephen Haddad, M.D
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
16. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Dr. Ghatan Dermatology
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
17. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Chevra Hatzalah Inc.
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
18. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Bio-Reference Laboratories,
Inc. (Followed to Plaintiff counsel email).*** Please make sure the box for in
section 9(b) is initialed and signed and dated on the bottom of the form.
19. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Custom Chemists (Followed
to Plaintiff counsel
*** Please make sure the box for in section 9(b) is
email).
initialed and signed and dated on the bottom of the form.
20. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Labcorp of America Holdings
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
21. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Avenue U Medical Care PC
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
22. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Hospital for Special Surgery
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
23. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Downstate Foot & Ankle
Podiatry, Bryan Makeower, DPM (Followed to Plaintiff counsel email).*** Please
make sure the box for in section 9(b) is initialed and signed and dated on the
bottom of the form.
24. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for New York Institute of
Otolaryngology & Aesthetic Surgery (Followed to Plaintiff counsel email). ***
Please make sure the box for in section 9(b) is initialed and signed and dated on
the bottom of the form.
25. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Dr. Allan Lebovitz, DDS
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
26. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Maimonides Midwood
Plaintiff counsel *** Please make sure
Community Hospital (Followed to email).
the box for in section 9(b) is initialed and signed and dated on the bottom of the
form.
27. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Castle Connolly Top Doctors
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
28. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Interborough Developmental
& Consultation Center (Followed to Plaintiff counsel email).*** Please make sure
the box for in section 9(b) is initialed and signed and dated on the bottom of the
form.
29. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Ume Farwa, OB/GYN
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
30. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Dr. Ephron Shohat, MD,
FACC *** Please make sure the box for in
(Followed to Plaintiff counsel email).
section 9(b) is initialed and signed and dated on the bottom of the form.
31. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEWYORK STATE) for Gregory Shifrin, OB/GYN PC
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
32. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Lyudmila Krupitsky
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
33. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Associated Dermatology
Center (Followed to Plaintiff counsel *** Please make sure the box for in
email).
section 9(b) is initialed and signed and dated on the bottom of the form.
34. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Talking Works, Dr. Lana
PhD (Followed to Plaintiff counsel *** Please make sure the box for
Gaiton, email).
in section 9(b) is initialed and signed and dated on the bottom of the form.
35. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Harry S. Shapiro, MD
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
36. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Medwell Womens Medical
PLLC *** Please make sure the box
Services (Followed to Plaintiff counsel email).
for in section 9(b) is initialed and signed and dated on the bottom of the form.
37. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEWYORK STATE) for Lori E Garjian, MD (Followed
to Plaintiff counsel *** Please make sure the box for in section 9(b) is
email).
initialed and signed and dated on the bottom of the form.
38. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Dr. Minsoo Cho, DDS
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
39. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Shirish Thanawala MD
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
40. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Highland Medical Rockland
Neurological Associates, Marianna Golden, MD (Followed to Plaintiff counsel
*** Please make sure the box for in section 9(b) is initialed and signed and
email).
dated on the bottom of the form.
41. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Memorial Sloan-Kettering,
Pediatric Division (Followed to Plaintiff counsel email).*** Please make sure the
box for in section 9(b) is initialed and signed and dated on the bottom of the form.
42. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
*** Please make
providerBeth Israel Deaconess Medical Center. sure the box for
in section 9(b) is initialed and signed and dated on the bottom of the form.
43. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for West Side Radiology
Associates Pc (Followed to Plaintiff counsel email).*** Please make sure the box
for in section 9(b) is initialed and signed and dated on the bottom of the form.
44. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
*** Please make
provider John Q. Pappas. sure the box for in section 9(b) is
initialed and signed and dated on the bottom of the form.
45. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Ramon Valderrama, MD
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
46. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
MD. *** Please make sure the box for in section 9(b)
providerJuana Lucia Cuevas,
is initialed and signed and dated on the bottom of the form.
47. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Barbara Gordon, MD
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
48. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
MD. *** Please make
providerMorton Zinberg, sure the box for in section 9(b) is
initialed and signed and dated on the bottom of the form.
49. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Constance Young, MD
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
50. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
MD. *** Please make
providerArnold Melman, sure the box for in section 9(b) is
initialed and signed and dated on the bottom of the form.
51. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Accupath Laboratories, Inc.
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
52. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
*** Please make sure the box for in section
providerOhel Jaffa Family Campus.
9(b) is initialed and signed and dated on the bottom of the form.
53. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Cath Char Nghbd Serves
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
54. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
*** Please
providerInna N. Yurkey Golger, MD. make sure the box for in section
9(b) is initialed and signed and dated on the bottom of the form.
55. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Rachel Kahan-Edlisz
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
56. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
*** Please make
providerSouthern Westchester Urgent Care PL. sure the box for
in section 9(b) is initialed and signed and dated on the bottom of the form.
57. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Luna Park Pharmacy
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
58. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
providerLDC Pharmacy Corporation.
*** Please make sure the box for in section
9(b) is initialed and signed and dated on the bottom of the form.
59. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Mott Haven Urgent Care
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
60. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
MD. *** Please make sure the box for in section
providerScot Bradley Glasberg,
9(b) is initialed and signed and dated on the bottom of the form.
61. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Aye Moe Thu Ma, MD.
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
62. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
*** Please
provider New York Presbyterian Hospital. make sure the box for in
section 9(b) is initialed and signed and dated on the bottom of the form.
63. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Sunrise Medical Laboratories
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
64. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION
PURSUANT TO HIPAA (NEW YORK STATE) for Bryan Makower, DPM
*** Please make sure the box for in section
(Followed to Plaintiff counsel email).
9(b) is initialed and signed and dated on the bottom of the form.
65. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
provider Brooklyn Surgery Center, LLC. *** Please make sure the box for in
section 9(b) is initialed and signed and dated on the bottom of the form.
66. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
provider Best Five Star Pharmacy, LLC. *** Please make sure the box for in
section 9(b) is initialed and signed and dated on the bottom of the form.
67. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for
providerIcahn School of Medicine at Mount Sanai. *** Please make sure the box
for in section 9(b) is initialed and signed and dated on the bottom of the form.
nd
Dated this 22I day ofAugust, 2023.
ANDERSONGLENN LLP
/s/ Amanda N. Rumker
John J. Glenn, Esquire
Florida Bar No.. 957860
jglenn@asglaw.com
Amanda N. Rumker, Esquire
Florida Bar Number: 125580
arumker@asglaw.com
2650 N. MilitaryTrial,Suite 430
Boca Raton, Florida 33431
(561) 893-9192 Phone
(561) 893-9194 Fax
CounselMDefendant
GG RE Hollywood Beach 613, LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 22r
nd
day of August, 2023, I electronically filed the
foregoing document with the Clerk of the Court using Florida Court's E-FilingPortal and certify
that all counsel of record have been served via transmission of Notice of Electronic Filing
generatedby Florida Court E-FilingPortal or in some other authorized manner for those counsel
or partieswho are not authorized to receive electronically
Notices of Electronic Filing.
/s/ Amanda N. Rumker
Amanda N. Rumker, Esquire
Preview
Filing# 180249366 E-Filed 08/22/2023 03:08:53 PM INTHE CIRCUIT COURT OF THE 17 ,TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-016578 JOY FURER, Plaintiff, V GG RE HOLLYWOOD BEACH 613 LLC, and RELAXPRO, LLC, Defendants. i DEFENDANT, GG RE HOLLYWOOD BEACH 613 LLC, THIRTEENTH REQUEST FOR PRODUCTION TO PLAINTIFF Defendant, GG RE HOLLYWOOD BEACH 613 LLC, by and through its undersigned counsel, and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby request that JOY Plaintiff, FURER, produce the followingwithin thirty(30)days of service hereof: 1. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Lenox Hill Hospital (Followed to Plaintiff counsel *** Please make sure the box for in section 9(b) is email). initialed and signed and dated on the bottom of the form. 2. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for East Side Endoscopy *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 3. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Dr. Arthur Lubitz (Followed *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/22/2023 03:08:53 PM.**** to Plaintiff counsel *** Please make sure the box for in section 9(b) is email). initialed and signed and dated on the bottom of the form. 4. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Joan V. Klein (Followed to Plaintiff counsel *** Please make sure the box for in section 9(b) is initialed email). and signed and dated on the bottom of the form. 5. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Outreach Outpatient Services *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 6. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for SLR Diagnostic Radiology *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 7. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Molina Healthcare of New *** Please make sure the box for York, Inc. (Followed to Plaintiff counsel email). in section 9(b) is initialed and signed and dated on the bottom of the form. 8. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Lenco Diagnostic Laboratories (Followed to Plaintiffcounsel email).*** Please make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 9. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Royal Care Pharmacy *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 10. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Boro Park OB/GYN (Followed to Plaintiff counsel *** Please make sure the box for in section 9(b) is email). initialed and signed and dated on the bottom of the form. 11. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for FJ Orthopaedics and Pain *** Please Management PLLC (Followed to Plaintiffcounsel email). make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 12. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Maiden Lane Medical, Harry Gruenspan, MD, PHD (Followed to Plaintiff counsel email). *** Please make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 13. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Manhattan Psychology PC *** Please make sure the box for Group, (Followed to Plaintiff counsel email). in section 9(b) is initialed and signed and dated on the bottom of the form. 14. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for ParCare Community Health Network (Followed to Plaintiff counsel *** Please make sure the box for in email). section 9(b) is initialed and signed and dated on the bottom of the form. 15. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Stephen Haddad, M.D *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 16. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Dr. Ghatan Dermatology *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 17. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Chevra Hatzalah Inc. *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 18. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Bio-Reference Laboratories, Inc. (Followed to Plaintiff counsel email).*** Please make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 19. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Custom Chemists (Followed to Plaintiff counsel *** Please make sure the box for in section 9(b) is email). initialed and signed and dated on the bottom of the form. 20. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Labcorp of America Holdings *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 21. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Avenue U Medical Care PC *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 22. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Hospital for Special Surgery *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 23. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Downstate Foot & Ankle Podiatry, Bryan Makeower, DPM (Followed to Plaintiff counsel email).*** Please make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 24. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for New York Institute of Otolaryngology & Aesthetic Surgery (Followed to Plaintiff counsel email). *** Please make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 25. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Dr. Allan Lebovitz, DDS *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 26. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Maimonides Midwood Plaintiff counsel *** Please make sure Community Hospital (Followed to email). the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 27. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Castle Connolly Top Doctors *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 28. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Interborough Developmental & Consultation Center (Followed to Plaintiff counsel email).*** Please make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 29. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Ume Farwa, OB/GYN *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 30. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Dr. Ephron Shohat, MD, FACC *** Please make sure the box for in (Followed to Plaintiff counsel email). section 9(b) is initialed and signed and dated on the bottom of the form. 31. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEWYORK STATE) for Gregory Shifrin, OB/GYN PC *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 32. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Lyudmila Krupitsky *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 33. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Associated Dermatology Center (Followed to Plaintiff counsel *** Please make sure the box for in email). section 9(b) is initialed and signed and dated on the bottom of the form. 34. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Talking Works, Dr. Lana PhD (Followed to Plaintiff counsel *** Please make sure the box for Gaiton, email). in section 9(b) is initialed and signed and dated on the bottom of the form. 35. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Harry S. Shapiro, MD *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 36. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Medwell Womens Medical PLLC *** Please make sure the box Services (Followed to Plaintiff counsel email). for in section 9(b) is initialed and signed and dated on the bottom of the form. 37. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEWYORK STATE) for Lori E Garjian, MD (Followed to Plaintiff counsel *** Please make sure the box for in section 9(b) is email). initialed and signed and dated on the bottom of the form. 38. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Dr. Minsoo Cho, DDS *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 39. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Shirish Thanawala MD *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 40. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Highland Medical Rockland Neurological Associates, Marianna Golden, MD (Followed to Plaintiff counsel *** Please make sure the box for in section 9(b) is initialed and signed and email). dated on the bottom of the form. 41. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Memorial Sloan-Kettering, Pediatric Division (Followed to Plaintiff counsel email).*** Please make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 42. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for *** Please make providerBeth Israel Deaconess Medical Center. sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 43. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for West Side Radiology Associates Pc (Followed to Plaintiff counsel email).*** Please make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 44. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for *** Please make provider John Q. Pappas. sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 45. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Ramon Valderrama, MD *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 46. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for MD. *** Please make sure the box for in section 9(b) providerJuana Lucia Cuevas, is initialed and signed and dated on the bottom of the form. 47. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Barbara Gordon, MD *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 48. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for MD. *** Please make providerMorton Zinberg, sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 49. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Constance Young, MD *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 50. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for MD. *** Please make providerArnold Melman, sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 51. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Accupath Laboratories, Inc. *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 52. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for *** Please make sure the box for in section providerOhel Jaffa Family Campus. 9(b) is initialed and signed and dated on the bottom of the form. 53. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Cath Char Nghbd Serves *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 54. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for *** Please providerInna N. Yurkey Golger, MD. make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 55. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Rachel Kahan-Edlisz *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 56. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for *** Please make providerSouthern Westchester Urgent Care PL. sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 57. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Luna Park Pharmacy *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 58. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for providerLDC Pharmacy Corporation. *** Please make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 59. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Mott Haven Urgent Care *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 60. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for MD. *** Please make sure the box for in section providerScot Bradley Glasberg, 9(b) is initialed and signed and dated on the bottom of the form. 61. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Aye Moe Thu Ma, MD. *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 62. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for *** Please provider New York Presbyterian Hospital. make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 63. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Sunrise Medical Laboratories *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 64. Executed AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA (NEW YORK STATE) for Bryan Makower, DPM *** Please make sure the box for in section (Followed to Plaintiff counsel email). 9(b) is initialed and signed and dated on the bottom of the form. 65. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for provider Brooklyn Surgery Center, LLC. *** Please make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 66. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for provider Best Five Star Pharmacy, LLC. *** Please make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. 67. Executed AUTHORIZATION TO DISCLOSE HEALTH INFORMATION for providerIcahn School of Medicine at Mount Sanai. *** Please make sure the box for in section 9(b) is initialed and signed and dated on the bottom of the form. nd Dated this 22I day ofAugust, 2023. ANDERSONGLENN LLP /s/ Amanda N. Rumker John J. Glenn, Esquire Florida Bar No.. 957860 jglenn@asglaw.com Amanda N. Rumker, Esquire Florida Bar Number: 125580 arumker@asglaw.com 2650 N. MilitaryTrial,Suite 430 Boca Raton, Florida 33431 (561) 893-9192 Phone (561) 893-9194 Fax CounselMDefendant GG RE Hollywood Beach 613, LLC CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 22r nd day of August, 2023, I electronically filed the foregoing document with the Clerk of the Court using Florida Court's E-FilingPortal and certify that all counsel of record have been served via transmission of Notice of Electronic Filing generatedby Florida Court E-FilingPortal or in some other authorized manner for those counsel or partieswho are not authorized to receive electronically Notices of Electronic Filing. /s/ Amanda N. Rumker Amanda N. Rumker, Esquire