On August 15, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Johnson, Willie,
and
Lifestyle Lift Florida East Pa,
Mucci, M.D., Wayne,
Scientific Image Center Management, Inc.,
for Professional Malpractice - Medical
in the District Court of Broward County.
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Filing # 20896635 Electronically Filed 11/24/2014 10:30:43 AM
ENO PEI by SUE Carey aie
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO.: CACE 14-015935 (14)
FLA. BAR NO. 305553
WILLIE JOHNSON,
Plaintiff,
vs.
WAYNE MUCCI, D.O.;
SCIENTIFIC IMAGE CENTER
MANAGEMENT, INC.;
LIFESTYLE LIFT FLORIDA EAST, P.A.
d/b/a LIFESTYLE LIFT; and LIFESTYLE
LIFT FLORIDA EAST, P.A. a/k/a
LIFESTYLE LIFT SKINCARE, LLC,
Defendants.
a,
MOTION TO COMPEL DEPOSITIONS
COMES NOW the Plaintiff, WILLIE JOHNSON, by and through undersigned
counsel and hereby files the within Motion to Compel Deposition of Defendant,
WAYNE MUCCI, D.O. and Defendant, LIFESTYLE LIFTs’ employees, former
employees and/or agents of LIFESTYLE LIFT, and as grounds would state as
follows:
1. Plaintiff has attempted to coordinate mutually convenient
dates to schedule the depositions of the Defendant and Defendant employees,
former employees and/or agents of LIFESTYLE LIFT, as follows:
a. Maria Demarti, Consultant
b. Nichole Ferguson, Surgical Tech
c. Meyling Hernandez, Scheduler
d. Catherine Tremblay, Surgical Tech
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 11/24/2014 10:30:43 AM.****e. Wayne Mucci, D.O.
f, The manager of Lifestyle Lift at the time Plaintiff was a
patient at Lifestyle Lift
g. The consultant who greeted the patients and performed the
initial intake of Plaintiff, Willie Johnson, at the time she was
a patient at Lifestyle Lift.
5. To date, counsel for the Defendants have not provided dates of
availability for the depositions of the above-listed witnesses.
WHEREFORE, for the foregoing reasons, Plaintiff, WILLIE JOHNSON,
respectfully request this Honorable Court to enter an Order compelling the
depositions of the above-listed Defendant and Defendant employees and/or
former employees to take place within the next thirty (30) days.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was
sent via the EPortal System this day of November, 2014, to all parties.
MALOVE HENRATTY, P.A.
Counsel for Plaintiffs
14 Rose Drive
Fort Lauderdale, FL 33316
(954) 767-1000
Servemalovehenratty@malovelawfirm.com
By:
Stephen L. Malove, Esq.
Fla. Bar No.: 305553
we
Document Filed Date
November 24, 2014
Case Filing Date
August 15, 2014
Category
Professional Malpractice - Medical
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Filing # 20896635 Electronically Filed 11/24/2014 10:30:43 AM ENO PEI by SUE Carey aie AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 14-015935 (14) FLA. BAR NO. 305553 WILLIE JOHNSON, Plaintiff, vs. WAYNE MUCCI, D.O.; SCIENTIFIC IMAGE CENTER MANAGEMENT, INC.; LIFESTYLE LIFT FLORIDA EAST, P.A. d/b/a LIFESTYLE LIFT; and LIFESTYLE LIFT FLORIDA EAST, P.A. a/k/a LIFESTYLE LIFT SKINCARE, LLC, Defendants. a, MOTION TO COMPEL DEPOSITIONS COMES NOW the Plaintiff, WILLIE JOHNSON, by and through undersigned counsel and hereby files the within Motion to Compel Deposition of Defendant, WAYNE MUCCI, D.O. and Defendant, LIFESTYLE LIFTs’ employees, former employees and/or agents of LIFESTYLE LIFT, and as grounds would state as follows: 1. Plaintiff has attempted to coordinate mutually convenient dates to schedule the depositions of the Defendant and Defendant employees, former employees and/or agents of LIFESTYLE LIFT, as follows: a. Maria Demarti, Consultant b. Nichole Ferguson, Surgical Tech c. Meyling Hernandez, Scheduler d. Catherine Tremblay, Surgical Tech *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 11/24/2014 10:30:43 AM.****e. Wayne Mucci, D.O. f, The manager of Lifestyle Lift at the time Plaintiff was a patient at Lifestyle Lift g. The consultant who greeted the patients and performed the initial intake of Plaintiff, Willie Johnson, at the time she was a patient at Lifestyle Lift. 5. To date, counsel for the Defendants have not provided dates of availability for the depositions of the above-listed witnesses. WHEREFORE, for the foregoing reasons, Plaintiff, WILLIE JOHNSON, respectfully request this Honorable Court to enter an Order compelling the depositions of the above-listed Defendant and Defendant employees and/or former employees to take place within the next thirty (30) days. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was sent via the EPortal System this day of November, 2014, to all parties. MALOVE HENRATTY, P.A. Counsel for Plaintiffs 14 Rose Drive Fort Lauderdale, FL 33316 (954) 767-1000 Servemalovehenratty@malovelawfirm.com By: Stephen L. Malove, Esq. Fla. Bar No.: 305553 we