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Filing # 144517531 E-Filed 02/24/2022 09:50:02 AM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR MARION COUNTY, FLORIDA
CIVIL DIVISION
VIRGINIA PHILLIPS,
Plaintiff, CASE NO: 2019-CA-0142
Vv.
DONALD LAMBERT and
DJS ROOT SCOOTER, INC.
a Florida Corporation,
Defendants.
/
RE-NOTICE OF TAKING VIRTUAL DEPOSITION DUCES TECUM
[Reschedules Deposition Previously Noticed for 2/21/22]
PLEASE TAKE NOTICE that the Defendants, DONALD LAMBERT and DJ’S ROOT
SCOOTER, INC., by and through undersigned counsel, will take the deposition by oral
examination, pursuant to the Florida Rules of Civil Procedure and the Florida Statutes, of the
person named below, at the time, on the date, at the hour and at the place indicated:
WITNESS DATE/TIME LOCATION
STEPHEN PYLES, M.D. Monday, February 28, 2022 Via Zoom, c/o:
at 3:15 P.M. Phipps Reporting
305 NE 1“ Street
Gainesville, FL 32601
Zoom
https reporting.zoom.us/j/96358961901? pwd: S2Noek80VjFVOUSZTGS; TZOeTRNQTO9
Dial: +1 646 876 9923 (US Toll)
Meeting ID: 96358961901
Passcode: 935316
before Phipps Reporting and Notary Public, or before their duly designated representative, for
discovery purposes, for use as evidence at trial, or both, or for such other purposes as are
Electronically Filed Marion Case # 19CA000142AX 02/24/2022 09:50:02 AM
(00393102-1
permitted under the applicable and governing rules. The deposition will continue from day to
day until completed.
The Deponent is requested to have with him at said time and place those items on the
attached Schedule “A.”
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been e-served
through the Florida Courts E-filing Portal to: Scott J. Liotta, Esquire, Dan Newlin & Partners,
7335 W. Sand Lake Road, Suite 300, Orlando, Fl 32819 at liotta._pleadings@newlinlaw.com this
24th day of February 2022.
s/ Michael S. Rywant
Michael S. Rywant, Esq.
Florida Bar No.: 240354
Primary email:msrywant@rywantalvarez.com
Secondary: service@rywantalvarez.com
nginn@rywantalvarez.com
Anthony J. Livingston, Esquire
Florida Bar No.: 0028050
Primary email:alivingston@rywantalvarez.com
Secondary: apilcher@rywantalvarez.com
ebridgewater@rywantalvarez.com
Rywant, Alvarez, Jones, Russo & Guyton, P.A.
2440 S.W. 76" Street, Ste. 130
Gainesville, FL 32608
(Tel) 352-333-3700 / (Fax) 352-333-3706
Attorneys for Defendants
cc: Phipps Court Reporting
(00393102
EXHIBIT A
RE: VIRGINIA M. PHILLIPS a/k/a VIRGINIA M. POPYK
DOB: xx/xx/1961
SSN: XXX-XX-8076
1. All medical records, office records, doctors' and nurses' notes, and all other data
pertaining to the diagnosis, treatment and care of the above patient, rendered by the
witness.
2. All medical records, office records, doctors' and nurses' notes, and all other data
pertaining to the diagnosis, treatment and care of the above patient, rendered by
any other health care providers that are in the possession of the witness.
3. All reports rendered by the witness to any party concerning the diagnosis, care and
treatment of the above patient.
4, All reports or correspondence prepared for attorneys by the witness, and all
correspondence received by the witness from attorneys.
All patient information forms or questionnaires, or any other information provided
by the patient.
A current bill for all services rendered by the witness pertaining to the diagnosis,
treatment and care of the above patient.
A current statement indicating the total amount of the bill that has been paid and by
whom. Please do not provide individual invoices or bills.
Any and all x-rays or diagnostic studies taken of the above patient by the witness or
by any other health care providers that are in the possession of the witness.
9. All records requested should be all inclusive and should in no way be limited to one
incident.
10. All emergency room records, notes, hospital records and all other data pertaining to
diagnosis, treatment and care of the above-named patient.
il. All images, x-rays, films, and scans including, but not limited to, CTs and MRIs
pertaining to diagnosis, treatment, and care of the above-named patient.
12, EVERY WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENT'S
CHART, INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET.
(00393102
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Filing # 144517531 E-Filed 02/24/2022 09:50:02 AM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR MARION COUNTY, FLORIDA CIVIL DIVISION VIRGINIA PHILLIPS, Plaintiff, CASE NO: 2019-CA-0142 Vv. DONALD LAMBERT and DJS ROOT SCOOTER, INC. a Florida Corporation, Defendants. / RE-NOTICE OF TAKING VIRTUAL DEPOSITION DUCES TECUM [Reschedules Deposition Previously Noticed for 2/21/22] PLEASE TAKE NOTICE that the Defendants, DONALD LAMBERT and DJ’S ROOT SCOOTER, INC., by and through undersigned counsel, will take the deposition by oral examination, pursuant to the Florida Rules of Civil Procedure and the Florida Statutes, of the person named below, at the time, on the date, at the hour and at the place indicated: WITNESS DATE/TIME LOCATION STEPHEN PYLES, M.D. Monday, February 28, 2022 Via Zoom, c/o: at 3:15 P.M. Phipps Reporting 305 NE 1“ Street Gainesville, FL 32601 Zoom https reporting.zoom.us/j/96358961901? pwd: S2Noek80VjFVOUSZTGS; TZOeTRNQTO9 Dial: +1 646 876 9923 (US Toll) Meeting ID: 96358961901 Passcode: 935316 before Phipps Reporting and Notary Public, or before their duly designated representative, for discovery purposes, for use as evidence at trial, or both, or for such other purposes as are Electronically Filed Marion Case # 19CA000142AX 02/24/2022 09:50:02 AM (00393102-1 permitted under the applicable and governing rules. The deposition will continue from day to day until completed. The Deponent is requested to have with him at said time and place those items on the attached Schedule “A.” CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been e-served through the Florida Courts E-filing Portal to: Scott J. Liotta, Esquire, Dan Newlin & Partners, 7335 W. Sand Lake Road, Suite 300, Orlando, Fl 32819 at liotta._pleadings@newlinlaw.com this 24th day of February 2022. s/ Michael S. Rywant Michael S. Rywant, Esq. Florida Bar No.: 240354 Primary email:msrywant@rywantalvarez.com Secondary: service@rywantalvarez.com nginn@rywantalvarez.com Anthony J. Livingston, Esquire Florida Bar No.: 0028050 Primary email:alivingston@rywantalvarez.com Secondary: apilcher@rywantalvarez.com ebridgewater@rywantalvarez.com Rywant, Alvarez, Jones, Russo & Guyton, P.A. 2440 S.W. 76" Street, Ste. 130 Gainesville, FL 32608 (Tel) 352-333-3700 / (Fax) 352-333-3706 Attorneys for Defendants cc: Phipps Court Reporting (00393102 EXHIBIT A RE: VIRGINIA M. PHILLIPS a/k/a VIRGINIA M. POPYK DOB: xx/xx/1961 SSN: XXX-XX-8076 1. All medical records, office records, doctors' and nurses' notes, and all other data pertaining to the diagnosis, treatment and care of the above patient, rendered by the witness. 2. All medical records, office records, doctors' and nurses' notes, and all other data pertaining to the diagnosis, treatment and care of the above patient, rendered by any other health care providers that are in the possession of the witness. 3. All reports rendered by the witness to any party concerning the diagnosis, care and treatment of the above patient. 4, All reports or correspondence prepared for attorneys by the witness, and all correspondence received by the witness from attorneys. All patient information forms or questionnaires, or any other information provided by the patient. A current bill for all services rendered by the witness pertaining to the diagnosis, treatment and care of the above patient. A current statement indicating the total amount of the bill that has been paid and by whom. Please do not provide individual invoices or bills. Any and all x-rays or diagnostic studies taken of the above patient by the witness or by any other health care providers that are in the possession of the witness. 9. All records requested should be all inclusive and should in no way be limited to one incident. 10. All emergency room records, notes, hospital records and all other data pertaining to diagnosis, treatment and care of the above-named patient. il. All images, x-rays, films, and scans including, but not limited to, CTs and MRIs pertaining to diagnosis, treatment, and care of the above-named patient. 12, EVERY WRITTEN PIECE OF PAPER INCLUDED WITHIN THE PATIENT'S CHART, INCLUDING A COPY OF ANY NOTATIONS ON THE FILE JACKET. (00393102