On December 15, 2015 a
Party Discovery
was filed
involving a dispute between
Rowars, Barry,
Rowars, Deborah,
and
Broward Cty,
for Neg - Premises Liability Commercial
in the District Court of Broward County.
Preview
Filing # 49486992 E-Filed 12/01/2016 10:49:22 AM
IN THE CIRCUIT COURT OF THE SEVENTEENTH
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
BARRY ROWARS AND L
DEBORAH ROWARS, E
CASE NO. CACE 15-022067-21 i
Plaintiffs,
vs.
BROWARD COUNTY,
Defendant.
/
AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM
CAS TO LOCATION ONLY)
TO: Samuel J. Simon, Esquire
Ansel & Miller, LLC
601 South Ocean Drive
Hollywood, Florida 33019
ssimon@anselmiller.com(service address)
PLEASE TAKE NOTICE that, pursuant to Florida Rules of Civil Procedure 1.310,
the undersigned counsel will take the depositions of:
Name: Records Custodian for Memorial Regional Hospital West
Date: December 9, 2016
Time: 10:00am
Place: Memorial Regional Hospital West
9050 Pines Boulevard
Suite 255
Pembroke Pines, Florida 33028
Upon oral examination before a Notary Public or any other officer authorized by law to take
depositions in the State of Florida. The deposition is being taken for the purpose of discovery,
for use at trial, or for such other purposes, as permitted under the applicable and governing
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 12/1/2016 10:49:21 AM.****CASE NO.: CACE 4006842 (5)
rules. The witnesses shall present with copies of Any and all records and reports,
medical records and reports, all psychological and/or psychiatric treatment records and
reports, counseling records, charts, X-rays, scans, MRIs or films, nursing notes, physician
notes, memoranda, financial and billing records, forms signed by the patient, testing
procedures and results, patient questionnaires, prescription records and any and all data in
your possession, or any department thereof, pertaining to the care, examination and/or
treatment pertaining to patient, BARRY ROWARS - DATE OF BIRTH: MP 7 ana
SOCIAL SECURITY NO.: i
Individuals who have a disability which may need accommodation should contact
the undersigned seven (7) days prior to the deposition.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of this Notice of Taking Deposition Duces Tecum has
been forwarded via E-Mail Transmission to the above named party on this ist day of December,
2016,
Joni Armstrong Coffey
Broward County Attorney
Governmental Center, Suite 423
115 South Andrews Avenue
Fort Lauderdale, Florida 33301
Telephone: (954) 357-7600
Telecopier: (954) 357-7641
County Attorney
Florida Bar No. 59757
ce: Esquire Deposition Solutions
Ftlauderdalescheduling@esquiresolutions.com
Document Filed Date
December 01, 2016
Case Filing Date
December 15, 2015
Category
Neg - Premises Liability Commercial
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 49486992 E-Filed 12/01/2016 10:49:22 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA BARRY ROWARS AND L DEBORAH ROWARS, E CASE NO. CACE 15-022067-21 i Plaintiffs, vs. BROWARD COUNTY, Defendant. / AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM CAS TO LOCATION ONLY) TO: Samuel J. Simon, Esquire Ansel & Miller, LLC 601 South Ocean Drive Hollywood, Florida 33019 ssimon@anselmiller.com(service address) PLEASE TAKE NOTICE that, pursuant to Florida Rules of Civil Procedure 1.310, the undersigned counsel will take the depositions of: Name: Records Custodian for Memorial Regional Hospital West Date: December 9, 2016 Time: 10:00am Place: Memorial Regional Hospital West 9050 Pines Boulevard Suite 255 Pembroke Pines, Florida 33028 Upon oral examination before a Notary Public or any other officer authorized by law to take depositions in the State of Florida. The deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes, as permitted under the applicable and governing *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 12/1/2016 10:49:21 AM.****CASE NO.: CACE 4006842 (5) rules. The witnesses shall present with copies of Any and all records and reports, medical records and reports, all psychological and/or psychiatric treatment records and reports, counseling records, charts, X-rays, scans, MRIs or films, nursing notes, physician notes, memoranda, financial and billing records, forms signed by the patient, testing procedures and results, patient questionnaires, prescription records and any and all data in your possession, or any department thereof, pertaining to the care, examination and/or treatment pertaining to patient, BARRY ROWARS - DATE OF BIRTH: MP 7 ana SOCIAL SECURITY NO.: i Individuals who have a disability which may need accommodation should contact the undersigned seven (7) days prior to the deposition. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of this Notice of Taking Deposition Duces Tecum has been forwarded via E-Mail Transmission to the above named party on this ist day of December, 2016, Joni Armstrong Coffey Broward County Attorney Governmental Center, Suite 423 115 South Andrews Avenue Fort Lauderdale, Florida 33301 Telephone: (954) 357-7600 Telecopier: (954) 357-7641 County Attorney Florida Bar No. 59757 ce: Esquire Deposition Solutions Ftlauderdalescheduling@esquiresolutions.com