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Filing # 143344795 E-Filed 02/04/2022 04:11:45 PM
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,
DJ’S ROOT SCOOTER, INC.
A Florida Corporation,
Defendants.
/
NOTICE OF TAKING VIRTUAL VIDEOTAPED DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the Defendant, DONALD LAMBERT AND DJ’S ROOT
SCOOTER, INC., by and through undersigned counsel, will take the deposition by Zoom
Videoconference, 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
Medical Records Custodian Thursday, February 10, Phipps Reporting
2022 305 NE 1“ Street
West Marion Community @ 3:00 p.m. Gainesville, FL 32601
Hospital
Zoom Videoconference Link To
Be Provided Prior to Deposition
Before Phipps Reporting, Court Reporters 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 permitted under the applicable and governing rules. The deposition will continue
from day to day until completed. The deponent is to have with him at his deposition those items
listed on Exhibit A attached.
Electronically Filed Marion Case # 19CA000142AX 02/04/2022 04:11:45 PM
(00381790-1
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 4th
day of February 2022.
/s/ Anthony J. Livingston
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.
302 Knights Run Ave., Suite 1000
Tampa, FL 33602
(Tel) 813-229-7007 / (Fax) 813-223-6544
Attorneys for Defendants
(00381790-1
EXHIBIT A
VIRGINIA M. PHILLIPS a/k/a VIRGINIA M. POPYK
DOB: XX/XX/XXXX
SSN: XXX-XX-XXXX
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.
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.
All reports rendered by the witness to any party concerning the diagnosis, care and
treatment of the above patient.
All reports or correspondence prepared for attorneys by the witness, and all
correspondence received by the witness from attorneys.
5. 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.
7. 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.
8. 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.
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.
11. 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.
(00381790-1
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Filing # 143344795 E-Filed 02/04/2022 04:11:45 PM 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, DJ’S ROOT SCOOTER, INC. A Florida Corporation, Defendants. / NOTICE OF TAKING VIRTUAL VIDEOTAPED DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the Defendant, DONALD LAMBERT AND DJ’S ROOT SCOOTER, INC., by and through undersigned counsel, will take the deposition by Zoom Videoconference, 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 Medical Records Custodian Thursday, February 10, Phipps Reporting 2022 305 NE 1“ Street West Marion Community @ 3:00 p.m. Gainesville, FL 32601 Hospital Zoom Videoconference Link To Be Provided Prior to Deposition Before Phipps Reporting, Court Reporters 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 permitted under the applicable and governing rules. The deposition will continue from day to day until completed. The deponent is to have with him at his deposition those items listed on Exhibit A attached. Electronically Filed Marion Case # 19CA000142AX 02/04/2022 04:11:45 PM (00381790-1 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 4th day of February 2022. /s/ Anthony J. Livingston 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. 302 Knights Run Ave., Suite 1000 Tampa, FL 33602 (Tel) 813-229-7007 / (Fax) 813-223-6544 Attorneys for Defendants (00381790-1 EXHIBIT A VIRGINIA M. PHILLIPS a/k/a VIRGINIA M. POPYK DOB: XX/XX/XXXX SSN: XXX-XX-XXXX 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. 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. All reports rendered by the witness to any party concerning the diagnosis, care and treatment of the above patient. All reports or correspondence prepared for attorneys by the witness, and all correspondence received by the witness from attorneys. 5. 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. 7. 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. 8. 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. 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. 11. 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. (00381790-1